Thomas J. Delaney

Norton Rose Fulbright US LLP

Thomas J. Delaney

Thomas J. Delaney



Tom Delaney advises international and domestic financial services firms including banks, savings associations, ILCs, fintechs, insurance companies, payment providers and investment funds with respect to their US compliance obligations. He is particularly adept at resolving regulatory, supervisory and structural impediments to client's corporate objectives. His experience includes advising domestic institutions and FBOs on licensing requirements and Bank Holding Company Act, Volcker Rule and International Banking Act compliance, as well as governance and risk management.  

Chambers USA 2021 reports that Tom is "highly sought after by financial services groups for his assistance with complex regulatory compliance issues" and that clients "praise him for his core strengths in banking enforcement matters." He is nationally recognized for his AML work. In addition to advising clients on compliance matters, 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.

Tom has been practicing law for more than 30 years, initially as an attorney with the US Treasury Department's Office of Thrift Supervision. Prior to practicing law, he served on the staff of the Financial Services Committee  of the US House of Representatives and on the staff of the US Senate. He has represented clients before the Federal Reserve, the Comptroller of the Currency,  the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC) and the Consumer Financial Protection Bureau (CFPB). He has also appeared before various state authorities, including in New York, California, Illinois, Florida and the District of Columbia. In addition to financial services firms, Tom has advised foreign governments on their establishment of regulatory and enforcement systems that conform with international standards, including those specified by such bodies as the OECD's Financial Action Task Force.

Professional experience

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JD, American University Washington College of Law, 1986

BA, Georgetown University, 1979

  • District of Columbia Bar
  • Advised an international bank on affiliate transaction and licensing considerations in connection with the restructuring of its platform for providing private banking services
  • Advised both seller and acquiring institutions with respect to regulatory due diligence and compliance with Bank Holding Company Act, Bank Merger Act, Federal Deposit Insurance Act and state and federal licensing requirements. 
  • Advised numerous bank investors on compliance with BHCA Control Rule thresholds
  • Advised money transmittal businesses in connection with FinCEN and state licensing requirements
  • Assisted numerous banks, savings associations, broker-dealers with the development of AML and sanctions compliance programs
  • Advised a complex globally active financial services firm on the design and execution of an AML/sanctions risk assessment
  • Advised on Volcker rule compliance including SOTUS and TOTUS exceptions
  • Represented a non-US bank in connection with an OFAC compliance that included a multi-jurisdictional internal review and a voluntary self-disclosure
  • Represented several non-US banks in connection with alleged violations of Bank Secrecy Act (AML) regulations
  • Legal 500 US, Leading Lawyer, Financial services regulation, The Legal 500, 2022 - 2023 
  • Chambers USA, Nationwide, Financial Services Regulation: Banking (Enforcement and Investigations), Chambers and Partners, 2021 – 2023