Terence Gilroy

Terence Gilroy

Baker & McKenzie LLP


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 financial institutions, corporates, and individuals on white collar and financial crime and sanctions compliance 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

  • Representing large European bank in OFAC and Department of Justice (DOJ) investigations relating to Russian sanctions compliance.
  • Represented large manufacturing company in DOJ investigation of business activities in Syria and Iran.
  • Advising US household consumer goods company on application of US economic sanctions measures to company's global operations.
  • Conducted investigation on behalf of US-headquartered physical commodities trading company with global operations into allegations of bribery by agents of non-US subsidiaries.
  • Advising US financial services company on application of US Bank Secrecy Act and FinCEN implementing regulations to company's operations.   
  • 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, on behalf of numerous clients in multiple sectors.
  • Managed internal response to investigation by the 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 of financial services company 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)


  • English

Panelist, "Sanctions & Anti-Money Laundering," GIR Live, November 2023

Panelist, "National Security, Sanctions and Export Controls Conference," Sandpiper Partner, October 2023

Panelist, "OFAC Sanctions Update," FIBA Annual AML Conference, March 2023

Panelist, "Creating a Best-in-Class ESG Compliance Program," ACI FCPA Conference, November 2022

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