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
Since the passage of the USA PATRIOT Act, US financial institutions have had to comply with actions taken by the Treasury Department in consultation with the Federal Reserve to identify persons or entities as "primary money laundering concerns," which can lead to the imposition of a range of potential "special measures," impacting the designated entity’s access to the US payments system. This SR Letter (25-3) is an update of guidance that the Federal Reserve has issued in the past to update…
Halloween is around the corner and the whistling sound you may be hearing is that of registered investment advisers who, for the third time since the passage of the USA Patriot Act, have once again whistled past the graveyard of AML regulation that has long applied to banks, broker dealers, insurance companies, and other RIAs affiliated with banks. Registered investment advisers to private equity, venture capital, and hedge funds will have two more years to convince FinCEN that expanded…
The action taken yesterday by the FDIC is a welcome recognition that under a risk-based approach to AML compliance, it is possible for financial institutions to confirm customer identities during the account opening process, without requiring customers to provide proof of their identities. For years, as technology has expanded the capability of financial institutions to confirm customer identities, the industry has requested the regulators to align CIP requirements with those expanded…
As the federal bank regulators move into the fourth and final phase of the EGRPRA mandated process to identify outdated or otherwise unnecessary regulatory requirements, banks, savings associations and other entities, such as industrial loan companies, will have an opportunity to comment on three categories of regulation: Banking Operations, Capital and the Community Reinvestment Act, each of which have been the focus of industry concern for the past several years.
In the…