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
Consumers who object to terms and conditions in finance contracts retain the ultimate option of dropping the underlying product and going to another provider, an option somewhat facilitated by the open banking regulation the CFPB issued last October.
As meritorious as the issues in this proposed rule may be, and they are far from new, Chair Chopra must recognize that his days leading the CFPB are numbered. Rather than resign or offer his resignation, as is customary for…
Travis Hill is the new Acting Chair of the FDIC. It looks like the staff of the FDIC may receive new coloring books to ensure that, under his leadership, the agency exercises its statutory mandates by coloring within, rather than outside of the lines. In his first statement, Acting Chair Hill laid out an ambitious agenda, which includes reevaluating policy initiatives undertaken by the prior administration that have been criticized by some as overreaching, particularly in the areas of bank…
This Order may become known as the third-party consultant, full employment program.
The Order requires the Bank to hire several third-party consultants to evaluate and suggest improvements to various aspects of its AML and Sanctions compliance procedures. One third-party consultant is to perform an end-to-end assessment of the bank's AML and Sanctions compliance programs, the findings from which are to be used to shape the Bank's Action Plan for improving its compliance operations.…
In this matter, the Bank's inability, over a five-year period, to satisfy terms specified in prior OCC Consent Orders directed at the Bank's AML compliance program, led the OCC to issue this new Consent Order, which imposes significant punitive measures against the Bank. These include requiring the Bank to give prior notice to its Examiner-in-Charge before offering new products or services, and restricting incentive-based compensation that could be paid to certain senior executives.
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