US Supervision of International and Foreign Banking

Venable advises foreign entities about U.S. regulatory constraints on acquiring control of various forms of U.S. financial institutions, limits on interactions of such institutions with entities under common control, and supervisory expectations for domestic and foreign operations of such organizations, such as under the Bank Holding Company Act, International Banking Act, Foreign Bank Supervision Enhancement Act, Foreign Corrupt Practices Act, Bank Secrecy Act, OFAC, and U.S. anti-money-laundering laws.

Our experience is extensive. Over the years, we have advised numerous state banking associations, whose members include foreign-owned banks, on proposed legislation, tax issues, and regulatory developments. We also have provided counsel to several European Union banks regarding establishment U.S. subsidiaries, branches, and offices.

Venable attorneys recently assisted a South American owner of a U.S. national bank, in the context of a transfer of its own shares to another foreign entity, about avoiding a violation of the Bank Holding Company Act through use of a divestiture trust. We also represented the Ministry of Foreign Relations of the French Republic in an investigation of a state-owned financial institution.

Government Experience

Our team includes attorneys who are focused on financial services and regulatory issues and regularly deal with, or formerly served as senior officials and legal counsel of, federal and state agencies responsible for the supervision of financial institutions, including:

  • Office of the Comptroller of the Currency
  • Federal Deposit Insurance Corporation
  • Federal Reserve Board
  • Federal Deposit Insurance Corporation
  • Financial Crimes Enforcement Network (FinCEN)
  • Federal Housing Finance Agency
  • Department of Housing and Urban Development
  • Federal Financial Institutions Examination Council
  • Financial Stability Oversight Council
  • Commodities Futures Trading Commission
  • Department of Justice
  • Department of Treasury
  • Securities and Exchange Commission
  • Office of Management and Budget
  • Federal Trade Commission


  • Chambers USA
    • Financial Services Regulation: Banking (Compliance), 2007 – 2016
    • Financial Services Regulation: Banking (Enforcement & Investigations), 2007 – 2016
  • U.S. News – Best Lawyers, Best Law Firms, Financial Services Regulation Law, 2012 – 2017, 2020, 2022
  • Legal 500, Financial Services: Regulatory, 2011 – 2023