Thomas G. Kennedy

Biography

Thomas G. Kennedy is Counsel in the Corporate & Business Group and focuses on regulatory and compliance matters, bringing more than 25 years of experience advising financial institutions on complex regulatory, governance, and risk-management issues. He has counseled broker-dealers, investment advisers, private equity and hedge funds, banks, and trust companies on building and maintaining effective compliance programs that align with business objectives. Thomas has also advised firms on a variety of transactional matters, including drafting and reviewing investment management, distribution, and fund agreements, and managing legal-related projects.

Thomas serves as a Compliance Director at the firm’s affiliate, 3iCO, LLC, where he works closely with wealth managers, private equity firms, and investment companies to design practical compliance strategies. Earlier in his career, he held senior compliance and anti-money laundering roles, as well as various legal and risk management roles at First Manhattan, Bessemer Trust, Aberdeen Asset Management, Citigroup, JPMorgan, and Morgan Stanley. He is a frequent speaker and published author on asset management regulation and securities compliance matters.

CLIENT EXPERIENCE

Investment advisers, hedge funds, commodity pool operators and advisers, and registered investment companies
Broker-dealers and principal underwriters
Private equity and private real estate managers
Commercial banks, trust companies, and credit unions

Insights

My Greatest Strengths

I can serve as both your outsourced counsel and your compliance officer.
I worked in-house for nearly 30 years, served as CCO for more than 20 of those years, and understand what clients should expect from a legal and compliance provider.
Very little phases me anymore—short of the truly catastrophic, most issues can be fixed.

I WANT YOU TO KNOW

I have managed dozens of examinations and enforcement actions by the SEC, FINRA, the CFTC, the NFA, and bank regulators, guiding matters to successful resolution and overseeing related remediation plans.
From my in-house seat, I handled the legal and compliance aspects of acquiring asset management firms, preparing firms for acquisition, and managing post-transaction integration.
I represented my firm before the U.S. Federal Reserve and the Office of the Comptroller of the Currency, and appeared before the Securities and Exchange Commission in connection with shaping Regulation R—the broker-dealer exclusions that permit banks and trust companies to engage in securities activities.
I have prepared requests for exemptions, no-action letter relief, and interpretive opinions on a wide range of regulatory issues with multiple agencies.
I have also helped firms navigate registration as investment advisers, broker-dealers, transfer agents, investment companies, commodity pool operators, and commodity trading advisers, as well as membership with the NFA, FINRA, and various exchanges and clearing entities.

WHAT MAKES ME UNIQUELY ME

While I know when to be serious, I also enjoy having fun. I’ve been told more than once that I should have tried stand-up comedy.
During college and law school, I worked as a freelance stagehand in New York City's motion picture industry and earned credits on several films and music videos.
I also played varsity football and rugby at Iona—an achievement that mattered enormously to my ego 30 years ago and still makes me smile.

WHAT DRIVES ME

I enjoy solving complex regulatory problems.
I’m especially motivated to help clients who now hold roles similar to those I once held.

Focus

Practice Focus

Investment Advisers, Registered and Private Funds, Commody Pools – Regulatory Compliance
Investment Management, Securities, and Commodities – Transactional
General Corporate Counseling – Joint Ventures, Partnerships, and Corporations
Bank Secrecy Act, Anti-Money Laundering & U.S. Sanctions

Industry Focus

Financial Services
Investment Management
Securities
Real Estate Investment Management