Erik Walsh represents financial institution clients in enforcement, compliance, and regulatory matters before the federal and state banking agencies, DOJ, OFAC, and other government agencies. He regularly represents domestic and foreign institutions in government and internal investigations, particularly in matters involving alleged anti-money laundering and sanctions compliance concerns, bank fraud, employee misconduct, and safety and soundness criticisms. Erik is a trusted advisor to clients on an array of regulatory compliance and corporate governance issues, as well as bank examination preparation and remediation. He also has a background in litigation on behalf of a wide variety of clients.
Erik is a former Senior Counsel in the Enforcement, Litigation, and Investigations Division at the Federal Reserve Bank of New York (FRBNY). While there, he led enforcement investigations against financial institutions and individuals, including matters involving violations of BSA/AML and OFAC regulations and FX market manipulation. He worked closely with federal, state, and foreign regulators and enforcement authorities in several multi-agency investigations. Erik also advised FRBNY's Supervision staff on regulatory compliance issues, negotiated enforcement actions, and assessed bank remediation.
Erik maintains an active and diverse pro bono practice, including litigation involving separated immigrant families and religious discrimination. Prior to the FRBNY, Erik 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 under non-public enforcement action for credit risk management criticisms.
- 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, co-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.
Perspectives
Credentials
Education
- J.D., Boston University School of Law, 2004
- B.A., SUNY College at Geneseo, 2001, cum laude
Admissions
- New York
- U.S. District Court, Southern District of New York
- U.S. 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
Activities
- Member, Banking Law Committee, New York City Bar Association
- Instructor, BSA/AML/OFAC Compliance Training Series, Institute of International Bankers