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Kathleen A. Scott

Senior Counsel

Kathleen A. Scott

New York

T:+1 212 318 3084

Kathleen A. Scott is a senior counsel in the New York office representing some of the world's largest international banks and other financial institutions concentrating on a broad range of financial services regulatory, anti-money laundering and privacy matters.

She represents financial institution clients with respect to the bank regulatory aspects of mergers and acquisitions, establishment of new banking organizations and nonbanking affiliates, and other transactions.

Kathleen also advises U.S. and non-U.S. banks, bank holding companies and other financial institutions on a broad range of federal and state regulatory issues affecting all their operations and interacts routinely with federal and state banking regulators. She has expertise regarding U.S. federal and state banking laws and regulations regarding banks as well as nonbank financial companies that might require licensing at the state level.

Kathleen also counsels financial institutions facing enforcement or other supervisory actions or investigations by state and federal regulators on their compliance with federal consumer, privacy and anti-money laundering legislation and regulations. More specifically, she handles compliance with the Gramm-Leach-Bliley Act for banks and other financial institutions and related financial privacy and information security matters. She also uses her regulatory expertise to advise financial institutions on a broad range of anti-money laundering compliance and enforcement issues.

She also is a member of the firm's global financial technology practice, advising on the U.S. financial services regulatory aspects of cryptocurrencies, the blockchain and smart contracts

Kathleen began her career as an attorney for the United States Department of Treasury and also served as an assistant counsel for the New York State Banking Department before going into private practice at two other major law firms in New York before joining Norton Rose Fulbright.

Since 2005, she has written a bi-monthly column on International Banking for the New York Law Journal. In addition, she is an editor of, and routinely contributes to, the firm's Financial Services: Regulation Tomorrow blog, which provides insight and commentary on the global financial regulatory environment.

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  • Education

    JD, American University, Washington College of Law, 1982
    BA, cum laude, Villanova University, 1979

  • Representative experience


    Financial Services Regulatory

    • Key quality control person for global regulatory compliance projects for two major American banking and financial services corporations
    • Handled U.S. regulatory matters in cross-border acquisition of a U.S. nonbank lender by a non-U.S. bank
    • Advised several non-U.S. banks on the Dodd-Frank Act's Volcker Rule implementation for non-U.S. banks
    • Advised major non-U.S. banks on permissible activities in the United States transacted from outside the United States
    • Obtained federal and state regulatory approvals for numerous U.S. and non-U.S. clients regarding establishment of new banking institutions, bank holding company and financial holding company status, mergers, acquisitions, and new products, including obtaining financial holding company status for the first majority government-owned non-U.S. bank to elect that status
    • Developed and implemented strategies for the U.S. expansion of a major non-U.S. bank, including obtaining all state and federal regulatory approvals
    • Drafted federal and state legislation and regulations on a variety of regulatory issues


    Corporate work

    • Developed and implemented strategies regarding, and obtained regulatory approvals for, internal reorganizations for certain U.S. banking organizations, including preparation of all corporate documents and regulatory applications
    • Drafting corporate governance documents relating to the establishment of new banks and non-bank financial institutions, their transactions, and their ongoing corporate matters
    • Reviewing and revising bank policies for conformance with applicable laws and regulations
    • Drafting financial institution inter-company agreements and advising on financial institution servicing agreements with third party vendors


    Data Privacy

    • Provided information on U.S. anti-money laundering and U.S. financial privacy laws for a major European business conglomerate and a major non-U.S. financial institution
    • Assisted with an ancillary privacy issue in a securities investigation for a multinational financial institution; review of privacy policies
    • Advised a consultant to a regulatory agency on statutory confidentiality provisions for banks and drafted policies and conducted training for the consultant's staff


    Anti-money laundering

    • Negotiated major enforcement actions from both the private sector and public sector for U.S. banks and U.S. offices of non-U.S. banks, and assisted clients with enforcement action compliance
    • Drafted significant number of federal regulations, particularly with respect to anti-money laundering laws


    Miscellaneous

    • Handled U.S. bank regulatory aspects of international initial coin offering (ICO)
    • Drafted significant amount of state legislation and regulations on financial matters, including the New York Banking Laws on the licensing and supervision of the U.S. offices of non-U.S. banks and on liquidations of New York State-chartered banks and state-licensed offices of non-U.S. banks
    • Extensive experience in bank liquidation matters, having assisted in the liquidation of the New York office of a major international bank and the liquidation of an uninsured "banker's bank" for the thrift industry, as day-to-day legal liaison between the New York State Banking Department and those conducting the liquidation, and supervisor of outside counsel and other consultants
  • Admissions
    • District of Columbia Bar
    • New York State Bar
  • Rankings and recognitions
    • Chambers USA, Nationwide:  Financial Services Regulation: Banking (Compliance), Chambers & Partners, 2014-2017
    • New York Metro Super Lawyers, banking, Thomson Reuters, 2007, 2009 - 2011, 2014 - 2018
    • Chambers Global, Latin America-wide: banking & finance, Chambers & Partners, 2012
    • Chambers Latin America, banking & finance, Chambers & Partners, 2012
  • Publications

    A prolific writer, Kathleen is an editor of, and regularly contributes to, the Financial Services: Regulation Tomorrow blog, which provides insight and commentary on the global financial regulatory environment. Since 2005, she has written a bi-monthly column for the The New York Law Journal on International Banking.

    Other recent publications include:


    New York Law Journal recent columns:

  • Speaking engagements

    Kathleen was an adjunct professor at the New York Law School and co-taught a seminar on The Bank Holding Company Act. She is also a frequent  presenter at industry conferences, client seminars and Norton Rose Fulbright events, and is a CLE presenter for continuing legal education providers on bank and other financial services regulatory issues.

    Her recent engagements include:

    • Moderator, "Whistleblowers, Reporting Up and the Professional Rules of Ethics," New York State Bar Association Business Law Section Annual Meeting, New York, New York, January 24, 2018
    • Presenter, "AML Compliance Basics for Lawyers," Lawline, November 14, 2017
    • Panel Chair, "Changes in Banking Regulation in the New Administration," New York State Bar Association Business Law Section Fall Meeting, New York, New York, October 13, 2017
    • Panelist, "FinTech developments – initial coin offerings," Norton Rose Fulbright's Financial services 40-minute briefings, October 5, 2017
    • Co-Presenter, "Blockchain and Smart Contracts: An Introduction," Marsh USA web seminar, July 27, 2017
    • Co-Presenter, "Bitcoin and Beyond: An Introduction," MyLawCLE web seminar, June 22, 2017
    • Panelist, "Government by Executive Order and Presidential Memoranda," Norton Rose Fulbright's Financial services 40-minute briefings, March 2, 2017
    • Panelist, "Fintech: Smart contracts and regulating for innovation," Norton Rose Fulbright's Financial services 40-minute briefings, January 5, 2017
    • Presenter, "Introduction to Banking -2016," Lawline, November 16, 2016
    • Presenter, " Non-U.S. bank operations in the United States," Lawline,  November 16, 2016
    • Panelist, "Compliance 2016: Hot Button Regulatory Issues and Enforcement Actions," New York Bankers Association 2016 Financial Services Forum, October 18, 2016
    • Panelist, "Virtual Currency & Cryptocurrency Issues," New York State Bar Association Business Law Section Fall Meeting, Tarrytown, New York, October 3, 2015
    • Speaker, U.S. bank regulatory matters, Annual Australian Financial Institution Symposium, Sydney, May 4-6, 2015
  • Memberships and activities
    • New York State Bar Association –Business Law Section, chair (2017-2018)
    • New York State Bar Association - Banking Law Committee, chair (2013-2016)
    • New York City Bar Association - Banking Law Committee, chair (2006 -2009)
    • New York Appleseed, Board of Directors, chairperson (2016-present)
    • ARIVA - Board of Directors, chairperson (2013 – 2017), Board Governance Committee, chair (2017-present)
  • Videos

    Preparing for the US Volker rules

    April 2014

    Preparing for the US prudential standards rules

    April 2014

  • Publications

    EU v US intermediate financial holding company regimes

    On 23 November 2016, the European Commission published draft legislative proposals to amend key pieces of the EU’s banking and resolution regimes covering the Fourth Capital Requirements Directive (CRD IV)1, Capital Requirements Regulation (CRR)2, Bank Recovery and Resolution Directive (BRRD)3and the Single Resolution Mechanism Regulation..

    February 21, 2017

  • News