Jerome Walker

Partner

Jerome Walker is a member of SNR Denton’s Corporate and Business Transactions practice. He focuses on regulation, supervision and compliance activities of commercial banks, investment banks, and the United States operations of international banks. Jerome’s practice crosses many sectors and spans multiple geographies. Jerome is a former senior attorney for the comptroller of the currency, a former general counsel and chief compliance officer for the US operations of HongkongBank and a former managing director and head of bank regulatory compliance for Deutsche Bank Americas. He previously was a partner at another law firm.

Representative Experience

United States

• Representation of a major US commercial bank in connection with the restructuring of its US check processing operations to meet state and federal regulatory and operational requirements.
• Representation of a major US commercial bank in connection with the restructuring of its securities clearing operations to meet state and federal regulatory and operational requirements.
• Representation of an Internet-based company in connection with its joint venture with a leading US bank to develop and launch a commercial transactional website in the US.
• Representation of a fund management company in connection with its investment in Citigroup in connection with Citigroup’s acquisition of Associates First Capital Corporation.
• Representation of a New York insurance company with its fraud and internal controls investigation in connection with approximately US$1 million of stolen and forged checks.
• Representation of a New York limited liability company in connection with the establishment of a registered broker dealer with operations in 11 states of the US.
• Representation of a New York corporation in connection with several significant United States Department of the Treasury (DOT), Office of Foreign Assets Control, issues related to engaging in transactions with Iranian-owned companies.
• Representation of a national bank in connection with structuring and obtaining regulatory approval to establish a Small Business Investment Corporation to invest in equity securities.
• Represented the US operations of an international bank with headquarters in South Korea in connection with a series of Bank Secrecy Act violations related to suspicious activity reporting, wire transfers, Know Your Customers requirements, filing currency transaction reports and other policy and procedures and internal control requirements under US, New York, California, Washington and Illinois law.
• Representation of the New York office of an international bank with headquarters in the United Kingdom in connection with multiple Rule 23-A issues arising out of affiliate lending transactions.
• Representation of a number of US commercial banks in upgrading their compliance program by identifying the key applicable state and federal banking laws; drafted appropriate compliance procedures and assisted with the implementation of the procedures.

International

• Representation of one of the world’s largest commercial banks in connection with restructuring its US securities processing operations to meet state and federal regulatory and operational requirements.
• Represented one of the world’s largest banks in establishing money service businesses in key markets across the US.

Asia Pacific

• Representation of the New York branch of an international bank with headquarters in China in connection with the development of its US Dollar-Renminbi Exchange Program.
• Representation of the New York branch of an international bank with headquarters in China in connection with compliance with the requirements of the USA PATRIOT Act.
• Representation of the New York branch of an international bank with headquarters in China in connection with compliance with the requirements of US sanctions programs administered by the US DOT, Office of Foreign Assets Control and the US State Department.
• Representation of an international bank with headquarters in Japan in connection with structuring its broker dealer and representative office operations in New York and California.
• Representation of a New York trust company subsidiary of an international bank with headquarters in Japan in connection with compliance with the requirements of the USA PATRIOT Act.
• Representation of a New York trust company subsidiary of an international bank with headquarters in Japan in connection with its annual review of its nominee partnership program.
• Representation of an international bank with headquarters in Japan in connection with its withdrawal from the US.
• Representation of a registered broker dealer subsidiary of an international bank with headquarters in Japan to assist with Securities and Exchange Commission and National Association of Securities Dealers compliance requirements.
• Representation of the New York office of an international bank with headquarters in Japan in connection with the establishment of its sweep account program.
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the Japan Financial Services Agency.
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department and the Federal Deposit Insurance Corporation (FDIC) related to the activities of a limited purpose trust company’s ability to engage in insured banking activities.
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department and the FDIC related to the merger of three international banks with headquarters in Japan and the creation of one of the largest banking groups in the world .
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department and the FDIC in connection with the use and expansion of an international banking facility by a limited purpose trust company.
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department and the FDIC related to the purchase and sale of federal funds.
• Representation of the trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department and the FDIC related to the voluntary termination of its federal deposit insurance.
• Representation of a trust company subsidiary of two international banks with headquarters in Japan in connection with obtaining approvals from the New York State Banking Department, the Federal Reserve Bank of New York and the FDIC related to a Community Reinvestment Act protest filed by Inner City Press/Community on the Move to block a planned merger of the parent companies of the subsidiary with another international bank.
• Representation of a trust company subsidiary of an international bank with headquarters in Japan in connection with an employee’s attempted sabotage of the trust company’s wire transfer, securities processing and reconciliation systems.
• Representation of the Monetary Authority of Singapore in connection with custody and fiduciary issues involving its US Dollar deposits in the US.
• Representation of an international bank with headquarters in South Korea in connection with the sale of its retail banking network to a bank in California.
• Representation of an international bank with headquarters in South Korea in connection with an enforcement action involving 11 US and state agencies.
• Representation of the New York office of an international bank with headquarters in South Korea in connection with its application to appeal the decision of the US DOT, Office of Foreign Assets Control, to block one of its customer’s accounts as the result of activities involving Iran.

Europe and the UK

• Representation of a securities subsidiary of an international bank with headquarters in France in connection with the development and launch of its website for securities and lending activities in the Americas.
• Representation of a private equity subsidiary of an international bank with headquarters in France in connection with structuring and obtaining regulatory approval to establish a US$300 million US private equity fund.
• Representation of an international bank with headquarters in France in connection with the acquisition of the global operations of a private banking group with headquarters in South Africa and the disposition of three US investment banking subsidiaries.
• Representation of an investment bank subsidiary of an international bank with headquarters in France in connection with the management buyout of two of its registered broker dealers.
• Representation of the New York office of an international bank with headquarters in France in connection with a credit administration and underwriting review of its treasury operations.
• Representation of the New York office of an international bank with headquarters in France in connection with the sale of its finance company subsidiary to a state-chartered bank.
• Represented the New York subsidiary of an international retail company with headquarters in Italy in connection with the recovery of more than US$300,000 in stolen and forged checks.
• Representation of an international hotel chain with headquarters in Malta in connection with its application to be removed from the Specially Designated Nationals List of the US DOT, Office of Foreign Assets Control, as the result of activities involving Libya.
• Representation of the New York branch of an international bank with headquarters in Norway in connection with its parent company’s merger with another international bank.
• Representation of a New York subsidiary of an international bank with headquarters in the UK in connection with the development and launch of its global private banking website.
• Representation of the US investment banking subsidiary of an international bank with headquarters in the UK in connection with a tax-driven structured finance product involving the US and the UK.

Middle East

• Representation of the New York office of an international bank with headquarters in the Middle East in connection with compliance with the Gramm Leach Bliley Act privacy and Financial Holding Company requirements.

Russia and the CIS

• Representation of a broker dealer subsidiary of an international investment bank with headquarters in Russia in connection with negotiations for clearing services with a leading US investment bank.
• Representation of an international investment banking group with headquarters in Russia in connection with a comprehensive review of its internal controls and compliance procedures.
• Representation of an international manufacturer of steel with headquarters in Russia in connection with its attempt to import steel into the US without the US Department of Commerce or the Office of the United States Trade Representative taking action against the manufacturer based on dumping or subsidies.

Organizations

• Member, New York County Lawyers' Association
• Member, New York State Bar Association
• Member, The Institute of Internal Auditors
• Member, American Bar Association
• Member, Institute of International Bankers Professional Liaison Committee
• Professional liaison, New York State Society of Certified Public Accountants, Anti-Money Laundering and Terrorist Financing Committee
• Board of Directors, New York University School of Law Alumni Association
• Member, Association of Certified Anti-Money Laundering Specialists

Publications

• "UK and US Comparison of Living Wills Requirements for Banks in the UK and US," Bloomberg Law Reports, December 23, 2011

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