Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Investigations Compliance and Ethics Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.
Representative Legal Matters
- Negotiated USD 2.5 million settlement with OFAC relating to alleged violations of OFAC's Zimbabwe Sanctions Regulations.
- Engaged directly with OFAC and US Department of State officials on issues relating to application of US economic sanctions, including those targeting Russia.
- Managed internal response to investigation by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into whether relationships with third parties who were retained to assist in winning or retaining business were compliant with the FCPA.
- Managed internal response to investigation by DOJ and SEC into hiring practices in Asia and other jurisdictions.
- Provided substantive briefings to the DOJ, SEC, U.K. Financial Conduct Authority (FCA), and U.K. Prudential Regulatory Authority (PRA) on various issues.
- Prepared and submitted to OFAC numerous voluntary self-disclosure (VSD) letters concerning potential violations of OFAC regulations.
- New York~United States (2007)
- St. John's University, School of Law (JD, cum laude) (2006)
- United States Military Academy (BS) (1997)
- Panelist, "Omnibus Accounts, Trusts, and Other Unique Agreements: How to Conduct Strong Due Diligence to Mitigate Your Risks," ACI Advanced Conference on Economic Sanctions Enforcement and Compliance, Washington, D.C., 24 April 2017
- Panelist, "Attorney-Client Privilege in Investigations and Audits," Strafford FCPA Seminar, New York, N.Y., 1 February 2017
- Panelist, "Preserving Attorney-Client Privilege During Corruption Audits and Investigations," ACI FCPA Conference, Washington, D.C., 1 December 2016
- Panelist, "The U.S. Government is watching – Are you at risk? AML, CTF, Economic Sanctions, the FCPA and the USA PATRIOT Act: What you need to know to protect your company," British American Business Association, Washington, D.C., 22 November 2016
- Panelist, "Government and Internal Investigations: Current Ethical, Privilege and Cooperation Issues," Shearman & Sterling Alumni CLE Series, New York, N.Y., 14 November 2016
- Panelist, "Ethics in Internal Investigations," Association of Corporate Counsel – Compliance Institute and Annual Meeting, New York, N.Y., 13 September 2016
- Speaker, "Interactive Discussion on How to Work Effectively with OFAC," ACI Economic Sanctions Enforcement & Compliance Conference, Washington, D.C., 28 April 2016
- Panelist, "Compliance with Economic Sanctions in the Broker-Dealer Context," SIFMA AML Conference, New York, N.Y., 6 April 2016
- Panelist, "Privacy and Confidentiality Issues in Cross-Border Internal Investigations," ACI FCPA Conference, Washington, D.C., 17 November 2015
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