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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.

In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments Conference. The conference will provide valuable insights on the latest developments, challenges and opportunities in the ever-changing landscape of international trade.
We are holding this conference in a split-hybrid format, with an in-person event in Santa Clara, CA, on 12 November and virtual panels on 19-21 November.

On 23 September 2024, the US Department of Justice Criminal Division issued an updated version of its Evaluation of Corporate Compliance Programs document. DOJ uses the Evaluation Guidance to assess the adequacy of compliance programs in place at companies subject to its criminal enforcement activities. DOJ has updated the Evaluation Guidance periodically since its release in 2017 to align with evolving DOJ policies, priorities, and compliance best practices. This latest iteration reflects current DOJ investigation and enforcement priorities and the increasing relevance of artificial intelligence and other emerging technologies to companies, their compliance programs, and DOJ’s enforcement efforts. DOJ also updated the Evaluation Guidance to encourage companies to: 1) incorporate a lessons-learned approach; 2) focus on compliance due diligence and integration in acquisitions; and 3) properly incentivize internal reporting of wrongdoing.

For the second week of our Annual Compliance Conference, we discussed key trade compliance issues impacting our clients globally. Specifically, we discussed the trade policy response of the US, EU and U.K. to ever increasing geopolitical disruption, global strategies for handling sanctions regulators and enforcement, and key global sanctions and export controls developments.

On August 14, 2023, the US State Department, the Labor Department, and the Commerce Department issued a business advisory (“Business Advisory”) highlighting key risks for companies operating in South Sudan.
While it does not impose new legal obligations on companies, the Business Advisory highlights the fact that list-based sanctions remain in force targeting certain South Sudanese persons including designations under the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, and the US Commerce Department’s Bureau of Industry and Security’s Entity List.

Baker McKenzie’s Sanctions Blog published the alert titled  OFAC and OFSI Issue Joint Humanitarian Assistance and Food Security Fact Sheet Relating to Russia on 11 July 2023. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.  

Baker McKenzie’s Sanctions Blog published the alert titled BIS, DOJ and OFAC publish compliance note warning public of Russian evasions of export controls and sanctions on 10 March 2023. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

Baker McKenzie is delighted to invite you to interactive seminars on 1 March 2023 in Abu Dhabi and 2 March 2023 in Dubai as part of our EMEA Russia Sanctions Briefings. The seminars will focus on the multijurisdictional sanctions challenges facing financial institutions and their clients and other corporates in the Gulf, in relation to the US, UK, EU and UAE sanctions regimes, particularly against Russia. We will also focus on the current enforcement environment and best practices for mitigating sanctions risk arising from potential compliance failures.