Kevin M. Toomey

Kevin M. Toomey

Senior Associate

Kevin Toomey represents banks and nonbank financial services companies, along with their boards of directors, executives, and senior management, in a wide range of enforcement, regulatory, compliance, and governance matters before the federal and state banking agencies, Department of Justice, CFPB, FinCEN, and OFAC. Mr. Toomey regularly represents clients in investigative proceedings, including navigating internal and government investigations, and advises clients on issues relating to the Bank Secrecy Act and anti-money laundering requirements, consumer protection, the Dodd-Frank Wall Street Reform and Consumer Protection Act, and state and federal banking laws and regulations.

Mr. Toomey also has significant experience counseling financial institutions on an array of corporate, securities, and transactional matters, including mergers and acquisitions, public and private securities offerings, and corporate reorganizations.

While attending law school, Mr. Toomey worked in the Enforcement Section of the FDIC, the Executive Office for US Attorneys at DOJ, and the US Attorney's Office for the District of Columbia.


  • National bank in an investigation under the Bank Secrecy Act brought by the Office of the Comptroller of the Currency, the Financial Crimes Enforcement Network, and the Department of Justice.
  • Large nonbank financial institution, before the DOJ, SEC and FDIC, in an investigation of alleged violations of securities laws.
  • Nonbank financial institutions in internal investigations relating to BSA/AML requirements.
  • Board of directors on corporate governance matters and enforcement proceeding brought by the New York Department of Financial Services.
  • Outside directors of a state-member bank's board in enforcement proceeding brought by the FDIC relating to BSA/AML matters.


DOJ Issues "First-of-its Kind" Enforcement Framework To Address Criminal Threats Associated With Cryptocurrency
Enforcement Edge: Shining Light on Government Enforcement
Arnold & Porter Discusses Waste and Abuse of Covid-19 Relief Funds
The CLS Blue Sky Blog
Banking & Finance Biweekly Update: AML Developments During the COVID-19 Crisis
Coronavirus: Financial Services Webinar
Tracking Fraud, Waste and Abuse of COVID-19 Relief Funds
Enforcement Edge: Shining Light on Government Enforcement
New BSA/AML Enforcement and Compliance Guidance
Enforcement Edge: Shining Light on Government Enforcement


Washington, DC Super Lawyers
"Rising Star"–Banking (2017-2020)


  • JD, Syracuse University College of Law, 2012
  • BA, Colgate University, 2007
  • District of Columbia
  • Maryland
Government & Military Service
  • Enforcement Section, Federal Deposit Insurance Corporation
  • Vice Chair, Bank Secrecy Act and Anti-Money Laundering Subcommittee of the ABA Banking Law Committee
  • Member, ABA Consumer Financial Services Committee
  • Instructor, BSA/AML/OFAC Compliance Training Series, Institute for International Bankers
  • Editorial Board, FinTech Law Report

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