Dillon Guthrie represents technology companies, investment firms, depository institutions, and other financial services businesses in complex regulatory, supervisory, enforcement, investigative, governance, and transactional matters. His practice spans US and cross-border regulatory regimes, with a focus on banking regulation, financial crimes, payments, digital assets, investigations, and strategic transactions.
Dillon represents clients before US and state regulatory authorities, including the Commodity Futures Trading Commission, Federal Deposit Insurance Corporation (FDIC), Federal Reserve, Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and Securities and Exchange Commission (SEC). He works with financial institutions on issues involving the Bank Holding Company Act, the Federal Reserve Act, and related banking statutes and regulations, including questions of control, permissible investments, affiliate relationships, capital and liquidity requirements, charters, and novel activities. His practice in cross-border, national security, and other sensitive regulatory contexts further encompasses anti-money laundering and sanctions compliance, counter-terrorist financing, cyber risk, fraud, and other financial-crime matters, including under the Bank Secrecy Act, the International Emergency Economic Powers Act, and other sanctions authorities.
Dillon’s payments experience includes domestic and international funds transfers governed by Article 4-A of the Uniform Commercial Code, Regulation J of the Federal Reserve, Nacha and Swift rules, and contractual obligations. He regularly supports banks and other firms in developing innovative digital asset and artificial intelligence infrastructures, and related products and services. Dillon also assists clients following outages, cyber breaches, and other security incidents, particularly involving sophisticated wire fraud and other illicit-finance activity.
Dillon is frequently called upon to represent clients in supervisory examinations, enforcement actions, internal and congressional inquiries, and corporate governance matters. He advises boards of directors, individual directors, and senior management on investigative and risk issues, including conflicts of interest, internal controls, cybersecurity, and risk management. His experience includes supervisory appeals and enforcement proceedings, as well as the design and enhancement of risk, cybersecurity, anti-money laundering, and sanctions compliance programs to remediate supervisory and other assessments.
In the transactional area, Dillon advises public companies and investment firms on mergers and acquisitions, capital markets transactions, early-stage investments, and other corporate and technology arrangements. His experience includes acquisitions and dispositions, spin-offs, joint ventures, restructurings, and financings in the energy, defense, banking, and semiconductor sectors. Dillon also has advised clients in responding to shareholder proposals and unsolicited bids, designing shareholder rights plans and other protective measures, and complying with the federal securities laws.
