Erik Walsh represents financial institution clients in enforcement, compliance and regulatory matters before the federal and state banking agencies, Department of Justice (DOJ), and the Office of Foreign Assets Control (OFAC). He regularly represents domestic and foreign institutions in government and internal investigations, particularly in matters involving Bank Secrecy Act/anti-money laundering (BSA/AML) compliance, OFAC sanctions compliance and bank fraud. Mr. Walsh regularly advises clients on BSA/AML and OFAC policies and procedures, environmental, social and governance (ESG) risk management matters, cannabis-related banking issues, and bank examination preparation and remediation. He also has a background in litigation on behalf of a wide variety of clients.

Mr. Walsh is a former Senior Counsel and Assistant Vice President in the Enforcement, Litigation, Police, Investigations & Corporate Affairs Division at the Federal Reserve Bank of New York (FRBNY). During his time there, he led enforcement investigations against financial institutions and employees, including significant matters involving violations of OFAC regulations and FX market manipulation. He worked closely with federal, state and foreign regulators and enforcement authorities in several cross-border, multi-agency investigations including the DOJ, Manhattan District Attorney's Office, New York State Department of Financial Services (DFS) and the UK Financial Conduct Authority (FCA). Mr. Walsh also advised FRBNY's Supervision staff on compliance issues and remediation at supervised financial institutions.

Mr. Walsh maintains an active and diverse pro bono practice, including litigation involving separated migrant families, religious discrimination, and prisoners' rights. Prior to the FRBNY, Mr. Walsh was an attorney at Arnold & Porter, where he focused on financial institution and securities litigation.

Experience

  • Financial institution in investigations conducted by DOJ and OCC relating to suspected mortgage fraud and violations of BSA/AML regulations.
  • Financial institution in connection with BSA/AML and bank fraud investigations conducted by DOJ, NYAG, and DFS.
  • Foreign financial institution in connection with a wide-ranging sanctions compliance investigation conducted by DOJ, NYAG, OFAC, the Federal Reserve and DFS.
  • At the FRBNY, led an OFAC sanctions-related investigation into a foreign financial institution that resulted in the highest civil money penalty ever issued by the Federal Reserve.
  • At the FRBNY, led investigations into several major global financial institutions concerning manipulation of the FX markets.
  • At the FRBNY, conducted investigations into individuals in connection with potential prohibition proceedings.

Credentials

Education
  • JD, Boston University School of Law, 2004
  • BA, State University of New York at Geneseo, 2001, cum laude
Admissions
  • New York
  • US District Court, Southern District of New York
  • US District Court, Eastern District of New York
Government & Military Service
  • Senior Counsel and Assistant Vice President; Enforcement, Litigation, Police, Investigations & Corporate Affairs Division; Federal Reserve Bank of New York
Overview

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