Partner
Norton Rose Fulbright US LLP
Tom Delaney is a Partner based in Washington, DC. He advises international and domestic financial services firms including banks, branches of foreign banks savings associations, ILCs, FinTechs, insurance companies, payment providers and investment funds with respect to US and cross-border compliance obligations. He advises on a wide range of issues, including compliance with the Bank Holding Company Act, the National Bank Act, the Federal Deposit Insurance Act and the Bank Secrecy Act. His strategic advice enables clients to resolve regulatory, supervisory, and structural impediments to their corporate objectives.
Additionally, Tom oversees the conduct of internal investigations, advises on remediation measures and aggressively defends financial services firms that become the target of enforcement proceedings and Congressional investigations.
Recent Articles & Comments
For those who thought that under President Trump, FinCEN would relax the fundamental AML program obligations that have historically applied to regulated financial institutions, think again. The current proposal begins with the statement that “FinCEN does not intend to finalize the (Biden Era) 2024 Program Notice of Proposed Rule Making” and that the 2024 NPRM should be considered withdrawn and superseded by the current NPRM. However, that does not mean that the current proposal reflects a…
The CRS correctly notes that implementation of the Corporate Transparency Act ("CTA") beneficial owner registration requirements has been choppy.
The CTA was passed on a substantially bipartisan basis in response to concerns that the U.S. had become an international outlier for not requiring LLCs and other corporate entities to disclose their beneficial owners, thereby facilitating potential money laundering by drug cartels, human traffickers and terrorist financiers.
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This action is more than a mere rescission of a policy statement. In his role as Deputy Chairman of the FDIC during the failure of Silicon Valley Bank, now Chairman Hill expressed concern about inefficiencies in the process that existed for marketing failed institutions to potential buyers. At the time, he identified a need for greater transparency and timeliness with respect to data concerning failed institutions, so that bidders and the FDIC could better understand and price the…
The rule that the Federal Reserve Board proposed yesterday will ban Board supervisory staff from rating bank lending practices on whether a bank’s credit decisions may give rise to reputational risk. This proposal aligns with the Administration’s broader supervisory objective to depoliticize credit (and other bank product) decisions, which was announced last year with the release of that targeted "debanking" based on a borrower’s political affiliation, religious beliefs or…