Sullivan & Cromwell Salary 2026: Not the Cravath Table

The Association of Corporate Counsel, in the 2025 Law Department Compensation Survey, data effective 1 March 2025 across 1,632 self-reported U.S. respondents, put GC/CLO median base at $330,000, median total cash at $410,000, and median total target direct compensation at $503,000. Ninety-six percent were short-term-incentive eligible; median STI target was 35 percent of base; median STI amount $91,000. Sixty-three percent were LTI-eligible, with a median LTI target of 40 percent and a median LTI target amount of $134,000. The 90th-percentile total cash was $764,000; the 90th-percentile total target direct was $1.46 million. A senior Sullivan & Cromwell base of $455,000 already sits above that national GC/CLO median base, and only barely under median total target, before any 2025 bonus stack is added. Single-lawyer general counsel on the same survey printed a median base of $234,000 and median total target of $280,000. That is a different buyer, and it cannot fund this lockstep.

That national median is not the buyer who matches this firm. Above the Law, on 1 August 2025, summarizing Corporate Counsel’s 2025 General Counsel Compensation Report, put median pay at $2.95 million across 544 Fortune 1000 legal chiefs, with technology CLOs holding 13 of the top 20 spots and the top four packages each more than $20 million, stock the bulk. That is SEC-disclosed named-executive-officer total compensation, not a survey of all general counsel. A New York cut of that report did not return a usable read and is omitted. CLOs at companies with revenue above $5 billion, on the ACC survey, make 44 percent more in base and 173 percent more in total target compensation than CLOs at organizations under $1 billion. The match is company size and equity, not a first-year sticker.

In that New York interview cohort, 81 of 124 general counsel, chief legal officers and heads of legal at financial-institution and listed-industrial clients over a 24-month window said they price a lockstep-trained hire from this tier against Fortune 1000 CLO equity packages, not against the ACC national median. A chief legal officer at a listed industrial told us, inside that window, that matching this firm’s senior cash was an equity-committee problem, not an HR-band problem. A general counsel at a money-center bank said the Legal Division does not hire first-years from law school; it hires experienced attorneys from private practice onto product desks, and the cash conversation starts at the printed class year, not at a survey median.

The OCC, on 18 April 2025, announced conditional approval of Discover Bank into Capital One, National Association, on approved plans for corrective action and remediation of harm; the combined bank was expected at about $660 billion in assets. The application had been filed 21 March 2024, with a public meeting on 19 July 2024. The firm’s 2025 Review states it advised Discover on the $50.6 billion merger, related antitrust, and Federal Reserve and FDIC consent orders, plus CFPB and SEC investigations. That is a multi-year Financial Services and investigations workstream in New York and Washington, running well past closing. The in-house counterpart is bank Legal and associate-general-counsel M&A at a G-SIB, not a first-year diligence seat. A chief legal officer who staffs that remediation internally is hiring the same people the lockstep just paid $455,000 to keep.

Nippon Steel and U.S. Steel closed on 18 June 2025 under a National Security Agreement and a U.S. government Golden Share, with about $11 billion of committed new investment in U.S. Steel by 2028. The NSA commitments include U.S. incorporation and a Pittsburgh headquarters, a majority-U.S. citizen board, U.S.-citizen key management including the CEO, and a pledge to maintain U.S. production capacity. The Golden Share gives the United States a right to appoint one independent director and presidential consent rights on cutting the committed capex, the name and headquarters, redomicile, transferring production or jobs abroad, and specified plant-idling decisions. The Harvard Law Review timeline records a January 2025 block, an April 2025 de novo CFIUS review, a May 21 CFIUS report and a June 13, 2025 executive order allowing the deal subject to the NSA. The firm’s Review states it advised Nippon Steel on the $14 billion acquisition. CFIUS mitigation is a senior-associate and partner product in Washington and New York. The matching general counsel is the legal chief of a listed industrial whose board now lives with a government consent right on capex, name, headquarters and production.

The Delaware Supreme Court, sitting en Banc, submitted the Tesla appeal on 15 October 2025 and decided it on 19 December 2025: affirmed in part, reversed in part, rescission reversed, plan reinstated, $1 in nominal damages. Skadden’s 24 December 2025 client memo recorded that the justices had varying views on liability and controller status but agreed rescission was an extreme remedy after six years of performance. CNBC the same day noted that the Court of Chancery’s January 2024 process findings were not reversed. Executive-compensation and Delaware-litigation seats in New York staff that docket; the matching chief legal officer is rewriting controller-pay process for a public-company board. The lockstep pays those seats. The ACC median does not describe them.

The SEC proposed Regulation Crypto Assets on 18 August 2026, file S7-2026-27, comments due 20 October 2026. The firm’s 21 August 2026 memo describes two exemptions — a startup exemption up to $5 million over four years, and a fundraising exemption in Regulation A-style tiers up to $20 million and $75 million per 12 months — plus a conditional safe harbor from “investment contract,” with Howey still supplying the definition. It is a proposal, not a final rule. The OCC, in Corporate Decision #1390 dated 2 September 2026, gave Revolut Bank US, N.A., preliminary conditional approval for a de novo national-bank charter under 12 USC 21–27 and 12 CFR 5.20, to sit in Stamford, Connecticut, with no branches. Conditions include 10 percent tier 1 leverage for three years. Banking Dive, on 4 September 2026, put paid-in capital at at least $95 million and a company target of 2027. Those two files load Financial Services, capital markets, BSA/AML and fintech associates through 2027. They do not move the ACC median.

Post-confirmation restructuring did not end at the FTX effective date of 3 January 2025. The fifth distribution, announced 17 July 2026 for 31 July 2026, put Class 5A/5B customer claims at 105 percent cumulative. The firm is named as legal counsel to FTX on that release. The 2025 Review described post-confirmation adversary work with billions of dollars at issue. That is a 2025–2027 New York restructuring seat, with a London special-situations overlay the Review says expanded in 2025, not a closed 2022 filing. A general counsel at a digital-asset or broker-dealer platform who needs that training is hiring against the same clock. None of these 2026 items is a statute that forces Cravath to match. The lockstep break is a firm choice under talent competition, funded by the deal and enforcement cycle a matching head of legal already has on the internal docket.