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 CFPB's action in these waning days of Director Chopra's tenure indicate that the agency remains resolute in pursuing payments companies that in its view fail to adequately protect the rights of consumers.
Although Google no longer offers the service that raised the CFPB's ire, as has been the case in actions brought by the CFPB and other federal financial regulators, exiting a business does not protect a company from potential enforcement action based on what the government…
The federal financial regulatory agencies have dutifully carried out their legal obligations under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 to review regulations and eliminate unnecessary requirements.
It is expected, however, that these efforts will have a substantially different tenor under the incoming administration, particularly in terms of what may be considered "unnecessary."
The availability of pass-through FDIC insurance coverage for funds maintained in custodial accounts is not a new concept.
It has long been the case that in the event of a bank's failure, FDIC coverage, up to statutory limits, would be provided to individual depositors as long as the entity responsible for placing the custodial account maintains records that are sufficiently detailed and up-to-date to enable the FDIC as receiver to determine amounts owed to individual depositors. As…
When it comes to meeting AML compliance requirements, firms cannot "mail it in." When expanding services to customers, firms have to consider whether the additional services or an expanded customer profile alters their AML risk assessment, and if so, what needs to be done procedurally, with respect to the implementation of controls, to manage additional risk to acceptable levels.
In addition to continually ensuring that customer due diligence procedures align with a changing customer…