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
The ABA is continuing its efforts to keep the Trump Administration focused on areas where changes to regulation and supervisory policy could result in administrative efficiency and reduced burden. While the Trump administration has generally indicated its support of such objectives and has rolled back changes to the CRA and Bank Merger Act regulations implemented during the Biden administration, the ABA continues to press for changes on issues such as on bank capital requirements that have…
For years, there has been recognition, among financial institutions and segments of the law enforcement community, that raising BSA reporting thresholds, along with other possible changes, could reduce burden without compromising the evidentiary and enforcement objectives of the BSA. The Senate bill is an important and overdue step in furthering that discussion.
In what is likely to be a trend, the OCC conditionally approved the charter of Erebor bank today. Erebor will be a full service insured national bank that plans to target its products and services to technology companies and ultra-high-net-worth individuals that utilize virtual currencies. In issuing this approval, the OCC found that the bank’s plan to hold non-asset backed virtual currencies on balance sheets to pay block-chain transaction fees (commonly referred to as "gas fees"), is…
While the FAQs do not reflect significant regulatory changes, they nevertheless move the needle in a positive direction in that they clarify financial institutions obligations to file updated SARs and to retain records when decisions are made to not file a SAR. These are helpful clarifications in reducing compliance burdens around the SAR filing process.