Patrick Fuller advises clients on a broad range of international, federal, and state bank regulatory, transactional, and enforcement matters.

Patrick has helped his clients structure business activities and corporate transactions, execute mergers, secure licenses and charters, raise capital from public and private markets, develop compliance programs, advocate for regulatory change, and respond to examinations, investigations, and enforcement actions. He has extensive experience in navigating complex strategic, structural, and compliance issues raised by U.S. regulatory reform initiatives, including the Dodd-Frank Act, the Volcker Rule, heightened prudential standards for large financial institutions, and more recent regulatory relief initiatives. He is also active in advising clients on regulatory issues impacting innovation and financial technology, and on compliance with U.S. anti-money laundering and sanctions laws and regulations. His clients include major U.S. and foreign banking organizations, private equity firms, asset managers, financial technology innovators, and trade associations.

Patrick joined the firm in 2008, became a senior attorney in 2017, and became counsel in 2022.

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Notable Experience

Regulatory Advice, Compliance and Advocacy

  • Numerous U.S. and non-U.S. banking organizations, including BNP Paribas, Credit Suisse, Goldman Sachs and HSBC, in all aspects of implementation of, and compliance with, the Volcker Rule

  • The Institute of International Bankers with respect to their advocacy to government agencies on Dodd-Frank matters on behalf of international banks, including in connection with the Volcker Rule and the Federal Reserve Board’s enhanced prudential standards for foreign banking organizations

  • Major U.S. and foreign banking organizations on compliance with the Bank Holding Company Act, the Gramm-Leach Bliley and Dodd-Frank, including the development of policies and procedures and on structuring new activities and investments

  • Multiple financial institutions and private equity firms, including TPG, on anti-money laundering and OFAC compliance matters, including developing anti-money laundering policies and procedures and implementation of FinCEN’s customer due diligence rules

  • A large financial institution in the launch of a new digital asset custody and transaction services business

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Transactional Highlights

  • Oriental Financial Group in its $500 million acquisition of BBVA’s Puerto Rico operations, and on two related capital markets offerings

  • American Express in the formation of a global business travel JV with an investor group led by Certares

  • A leading international banking group in the restructuring of its investment in an alternative investment management firm and in numerous minority investments in non-banking companies and funds

  • Credit Suisse in the bank regulatory aspects of numerous strategic transactions, including its investments in two newly formed Brazilian asset management companies, the spin-offs of Credit Suisse Quantitative and Systematic Asset Management, DLJ South American Partners and DLJ Merchant Banking Partners and the sale of its Customized Fund Investment Group

  • U.S. and foreign financial institutions, including BNP Paribas, Credit Suisse, Goldman Sachs, Natixis, and Santander, on regulatory issues for strategic and minority investments in non-banking companies and private equity funds

  • Major private equity firms, sovereign wealth funds, hedge funds and individual investors regarding regulatory considerations related to investments in banking organizations

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Enforcement

  • A large regional bank in a dispute with the FDIC over deposit insurance assessments

  • Numerous banking organizations on responses to examination criticism and public and private enforcement actions, remediation efforts, and operational consequences of ratings downgrades

  • Several major financial institutions on investigations and settlements concerning FX markets, LIBOR, ISDAFIX, FCPA compliance and other enforcement matters

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Selected Activities

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  • Faculty; Financial Institutions, Markets, and Transactions Training Series; 2022-2023

Publications