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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 Sanctions

United States: BIS Issues Temporary Denial Order Against Additional Russian Airline and Adds Aircraft to List of Aircraft Subject to General Prohibition 10

by , , and 1 Min Read

Baker McKenzie’s Sanctions Blog published the alert titled United States: BIS Issues Temporary Denial Order Against Additional Russian Airline and Adds Aircraft to List of Aircraft Subject to General Prohibition 10 on 2 June 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

In Belarus

United States: US Government imposes expansive OFAC sanctions on Russia, sanctions certain additional Belarussian entities

by , and 1 Min Read

Baker McKenzie’s Sanctions Blog published the alert titled “US Government imposes expansive OFAC sanctions on Russia, sanctions certain additional Belarussian entities” on 27 February 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

In North America

United States: OFAC amends and reissues Transnational Criminal Organizations Sanctions Regulations

by , and 3 Mins Read

The US Treasury Department’s Office of Foreign Assets Control issued a final rule amending and reissuing the Transnational Criminal Organizations Sanctions Regulations, to further implement two existing Executive Orders related to transnational criminal organizations: “Blocking Property of Transnational Criminal Organizations,” and “Taking Additional Steps to Address the National Emergency With Respect to Significant Transnational Criminal Organizations.”

In ESG

United States: OFAC Publishes Final Rule Amending the Syrian Sanctions Regulations

by , and 2 Mins Read

On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 to authorize nongovernmental organizations to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria.

In AML & Financial Services Regulatory

North America: Criminal proceeds – When does the “taint” expire?

by 1 Min Read

In this article published in The Review of Securities & Commodities Regulation, Thomas Firestone and Terence Gilroy provide an overview of the elements of criminal money laundering under US law and consider when a person is deemed to have knowledge that a transaction involves the proceeds of crime. They then suggest criteria to apply in determining whether assets remain tainted as the connection with criminal activity becomes more attenuated.

In Asia-Pacific

US Government Issues Cambodia Business Advisory on High-Risk Investments and Interactions; OFAC Sanctions Cambodian Government Officials

by , and 6 Mins Read

On November 10, 2021, the US Departments of State, Treasury, and Commerce issued a joint advisory (the “Advisory”) cautioning US companies operating in or considering operations in Cambodia to be conscious of dealings with entities and in sectors potentially involved in human rights abuses, criminal activities, and corrupt business practices. We describe the Advisory in additional detail below.

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