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
You can fold, but you can get called for violations of AML obligations.
What is particularly notable about this announcement is that Silvergate was voluntarily liquidating Silvergate Bank, a California chartered bank that provided financial services to foreign and domestic entities, including the bankrupt FTX, which traded on the bank's affiliated Silvergate Exchange Network. In addition to entering into a consent agreement with the Federal Reserve, Silvergate has entered into a…
While there are limited categories of SARs filings that can be made within FinCEN's current time estimates, financial institutions and regulatory officials know full well that preparing an accurate and appropriately comprehensive SAR filing, particularly when the underlying facts concern complex multi-party, and at times, multi-jurisdictional transactions, can be well in excess of 2 hours. The failure on the part of an institution to file a comprehensive SAR, deprives law enforcement of an…
It is relatively unusual for the FDIC to approve deposit insurance applications for an industrial loan company ("ILC"). Essentially, the approval of the merger transaction results in a Wisconsin credit union converting to an industrial loan company.
This is significant for a couple of reasons. First, the FDIC is generally reluctant to approve deposit insurance applications for ILCs because they are generally viewed as a loophole to parent company regulation under the Bank Holding…
This action by the FDIC to expand the scope and specificity of resolution plan filing requirements reflects continuing reverberations in the financial services regulatory realm caused by the failures of Silicon Valley Bank, Signature Bank and First Republic Bank in the Spring of 2023. Prior to each failure, none of these regional banks were regarded as systemically significant, but when they failed, the FDIC (and the Federal Reserve) quickly learned that their failures played an outsized…