Sterling Darling

Sterling is a counsel in the Washington D.C. office. He has extensive experience advising international financial institutions and global banks; energy exploration, production and pipeline companies; and multinational corporations located throughout the United States, Asia, the United Kingdom and Europe regarding U.S. economic sanctions and export controls, as well as other U.S. risk issues including anti-money laundering, bribery and corruption, financial regulation, and securities law. 

Sterling often draws on his experience in the firm’s New York office (2007-2014) as a derivatives, structured products and banking litigator to advise on issues relating to complex financial structures and products. While in New York Sterling was seconded to the firm’s London office and to the New York office of a multinational universal bank. After New York, Sterling was based in the firm’s Hong Kong office between 2015 and 2018, and is now based in Washington, D.C. 

With regard to economic sanctions, Sterling regularly advises state owned entities seeking to comply with U.S. sanctions and to address compliance with other U.S. laws and regulations; clients on sanctions risk relating to derivatives, structured product and other financial product transactions; buyers and financing banks in connection with the acquisition of sanctions impacted assets, including high-profile assets such as the Rhum Field; and a wide range of other clients in connection with corporate and capital markets transactions impacted by sanctions issues. Sterling has led sanctions-related due diligence exercises regarding target companies operating in China, Ireland, Nigeria and the United States, and has led bribery and corruption-related due diligence exercises regarding target companies located in those jurisdictions and throughout Europe, India, Indonesia, Myanmar, the Philippines, Singapore and Vietnam.

He also continues to assist financial institutions and other clients with regulatory enquiries and internal investigations, and to advise them on a range of U.S. litigation issues. 

Prior to joining Linklaters Sterling was a law clerk to the Honorable Myron H. Bright of the United States Court of Appeals for the Eighth Circuit.

Work highlights

Sterling was recently involved in the defense of:

• Energy companies and financing parties: advising on U.S. sanctions issues, in particular under the Russia and Venezuela sanctions programs.
• State owned entities: advising on risk arising under U.S. primary and secondary sanctions in connection with their lending activities.
• Telecommunications and technology companies: advising on emerging export control and sanctions issues, including in connection with the license requirements on the Chinese multinational technology corporation Huawei.
• A multinational extractives company: advising on bribery and corruption risk in relation to its dealings in a higher risk jurisdiction.
• A multinational financial services company: advising on its dealings in Venezuela following the imposition of sanctions.
• A multinational investment bank and financial services company: advising on regulatory investigations concerning its wealth management division and separately concerning its anti-money laundering compliance framework.

Sterling has a bachelor’s Degree from Harvard College and holds a Juris Doctorate, cum laude, from Georgetown University Law Center. He is a John M. Olin Fellow in Law and Economics.