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Terence Gilroy

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Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Compliance and Investigations 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.

On April 28, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule amending and reissuing the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) to further implement two existing Executive Orders, Executive Order 13536 of April 2010 and Executive Order 13620 of July 2012, and to replace the prior Somalia Sanctions Regulations that were published in May 2010 in abbreviated form.

On April 1, 2021, President Biden signed Executive Order 14022, revoking Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control…

The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (MEC) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (MEHL), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant…

On 1 February 2021, FINRA issued its 2021 Report on FINRA’s Examination and Risk Monitoring Program (“FINRA Report”) and a bit more than a month later, the SEC’s recently renamed Division of Examinations issued its own 2021 Examination Priorities (“Exam Priorities”). Each of these documents is quite long, with the FINRA report at 44 pages and the Exam Priorities document at 36 pages, and although there are some differences in focus and scope, we did find some common themes, which we have chosen to highlight in what we hope will be a helpful summary.

On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove Sudan’s designation as a State Sponsor of Terrorism (SST) (the “Amendments”).  The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing…

Baker McKenzie’s Government Enforcement Practice Group would like to wish you a Happy New Year. We have all taken some time off for the holidays, and a lot has happened in the interim. Perhaps most significantly, Congress passed, over President Trump’s veto, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). The most ballyhooed aspect of the NDAA, from a white-collar criminal law standpoint, has been the de facto elimination of anonymous shell companies — The Corporate Transparency Act, which is discussed below. However, the NDAA also included a number of other key provisions buried in the text, which are certain to assist the Government in its prosecution of white collar crime as well as increase compliance obligations on businesses. We have put together this note to clients and friends for the purpose of quickly updating you on these developments in a single document.

During the first two weeks in January, the Office of Foreign Assets Control (OFAC) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the…

Baker McKenzie’s Government Enforcement Practice Group would like to wish you a Happy New Year. We have all taken some time off for the holidays, and a lot has happened in the interim. Perhaps most significantly, Congress passed, over President Trump’s veto, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). The most ballyhooed aspect of the NDAA, from a white-collar criminal law standpoint, has been the de facto elimination of anonymous shell companies — The Corporate Transparency Act, which is discussed below. However, the NDAA also included a number of other key provisions buried in the text, which are certain to assist the Government in its prosecution of white collar crime as well as increase compliance obligations on businesses. We have put together this note to clients and friends for the purpose of quickly updating you on these developments in a single document.

Over the past two weeks, the Office of Foreign Assets Control (“OFAC”) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the development of…

Welcome to our first Virtual Year-End Review of Import/Export Developments Conference, a virtual offering for all our clients and friends worldwide. Baker McKenzie’s international trade compliance lawyers from around the world discussed the major global legislative, judicial and administrative activities and trends in export controls, trade sanctions, customs compliance, and…