Della Sentilles

Della Sentilles, a partner in Steptoe's Investigations, White-Collar & Compliance practice, has extensive experience handling complex internal investigations, advising on compliance programs, and trying high-stakes white-collar cases across the country. For more than a decade, Della served as a federal prosecutor with the US Department of Justice (DOJ) and, more recently, as an in-house advisor to a major US financial institution. Her dual background gives her a rare combination of litigation experience, regulatory insight, and practical business judgment that clients rely on when facing government scrutiny.

Prior to Steptoe, Della joined the DOJ through the highly selective Attorney General’s Honors Program, where she served in both the Money Laundering and Asset Recovery Section (MLARS) and the Fraud Section. She brings rare, first-of-its-kind experience to the firm, having led groundbreaking prosecutions in securities and commodities. She tried the first-ever criminal charges for insider trading involving the use of Rule 10b5-1 trading plans, securing convictions on all counts. She also brought and resolved the first-ever criminal case establishing insider trading liability in commodities under Rule 180.1, effectively setting the blueprint for how these matters are charged today, including in prediction markets. Della advises clients with unmatched clarity in emerging enforcement areas because she has not only practiced in this space — she helped create it.

Della also served as a prosecutor in the Fraud Section’s Foreign Corrupt Practices Act (FCPA) Unit, where she led complex international investigations and secured corporate resolutions involving subsidiaries of four multinational companies. She has firsthand experience with the DOJ’s corporate enforcement policies and deep insight into how prosecutors assess voluntary disclosure, cooperation, and remediation. Her work coordinating with foreign regulators, navigating data privacy regimes, managing parallel Securities and Exchange Commission matters, and conducting interviews across multiple jurisdictions equips her to guide clients through cross-border enforcement matters with precision and credibility.

In addition to her FCPA work, Della investigated and prosecuted high-profile matters across the Fraud Section involving federal program fraud, securities fraud, commodities offenses, bank fraud, wire fraud, honest services wire fraud, mail fraud, and money laundering. She first-chaired or co-chaired six federal white-collar jury trials to verdict, securing convictions in all. Her ability to simplify complex financial concepts for juries and anticipate government strategy enables her to help clients assess litigation risk accurately and position matters for the strongest possible outcome.

During her time at MLARS, Della litigated some of DOJ’s most complex international forfeiture matters against assets belonging to high-profile foreign officials. Her work on the first-ever civil forfeiture action against an EB-5 visa investment, based in part on foreign law, earned her the Attorney General’s John Marshall Award, the DOJ’s highest honor. This experience gives her unique subject matter expertise in asset forfeiture and positions her to help clients anticipate risk and respond effectively to seizures.

More recently, Della served in a senior role at Morgan Stanley, where she oversaw its compliance with the Bank Secrecy Act (BSA) and assisted with regulatory inquiries and its expansion into cryptocurrency. Due to her combined experience as a prosecutor and in-house counsel, she understands how regulators evaluate potential violations; how companies balance risk with business objectives; and how to frame issues in a way that minimizes escalation. This perspective allows her to help clients respond strategically to government scrutiny and build compliance programs that withstand regulatory expectations.