J. Paul Caulfield is head of Ruddy Gregory’s Financial Regulation and Cybersecurity practices, representing foreign banking organizations (FBOs), large, regional and community banks, investment management firms, and global service providers in the financial and fintech communities.
Paul’s work has involved matters throughout Latin America, Israel, China, Hong Kong and India and, increasingly, matters involving large language models (LLMs) and artificial intelligence (AI), data encryption and blockchain technology. Mr. Caulfield has his Series 7, 24 and 63 securities licenses and is certified in both information systems security (CISSP) and anti-money laundering (CAMS).
Prior to his work at Ruddy Gregory, Mr. Caulfield served in executive positions across law, risk, compliance and cybersecurity, as chief legal officer and COO for a U.K. provider of investment research, chief risk officer, chief compliance officer and BSA officer for Israel’s largest overseas financial services institution, and head of compliance for Citibank N.A.’s U.S. Commercial Bank. Paul has worked with and sat on boards of directors, resolved numerous public and private regulatory matters and threatened litigation, and bolstered GRC (governance, risk and compliance) and cybersecurity programs for highly and newly regulated market participants, including establishing enterprise-wide cybersecurity and cross-border data protection programs.
Mr. Caulfield has managed nearly every aspect of regulatory supervision in financial services, including targeted reviews, surprise inspections, full-scope safety-and-soundness examinations, public and non-public supervisory actions and transitions from community to regional bank programs. He has spoken and written extensively on regulatory risk management, financial crimes compliance, financial technology and cybersecurity. In addition to his legal work, Paul is the founder of Legal Risk Solutions, LLC, a provider of technology applications for heads of legal and compliance. He holds a patent in information sharing and is an adjunct professor at Fordham University School of Law, where he teaches a course on effective financial crimes risk management. He began his career in the Manhattan District Attorney’s Office.
BAR ADMISSIONS
- New York State
- United States District Court for the Southern District of New York
- United States District Court for the Eastern District of New York
- Washington, D.C.
EDUCATION
- J.D., Catholic University of America, Washington, D.C., 2001
- B.A. in Political Science, Fairfield University, Fairfield, CT, 1996
CERTIFICATIONS & LICENSES
- Certified Information Systems Security Professional (CISSP)
- Certified Anti-Money Laundering Specialist (CAMS)
- Series 7, 24 and 63 Securities
ACADEMIC
- Adjunct Professor, Fordham University School of Law, 2019 - Present
RECENT REPRESENTATIVE MATTERS
- Governance, Risk and Compliance Program to assist buy- and sell-side clients managing insider trading risks in SEC (U.S.), FCA (U.K.), CSRC (China), SFC (Hong Kong) and SEBI (India) jurisdictions, 2022 – 2023
- Compliance and Risk Management Programs for China’s Anti-Espionage Law, 2023
- Favorable settlement of multi-million dollar class action suit alleging wage and hour violations, 2022
- Compliance Program for China’s Personal Information Protection Law (PIPL), 2021
- Governance, Risk and Compliance Program for Regional Bank Supervision by the Federal Deposit Insurance Corporate, Federal Reserve Bank of New York and New York State Department of Financial Services, 2020
- Compliance Management System and Fair Lending Compliance Program for Consumer Financial Protection Bureau, 2020
- Cybersecurity Program for New York State Department of Financial Services, 23 NYCRR Sec. 500, 2018
- Anti-Money Laundering Transaction Monitoring and Filtering Program for New York State Department of Financial Services, 23 NYCRR Sec. 504, 2017
- Compliance Program for FinCEN’s Customer Due Diligence Rule, 2016
- Compliance, Risk Management and Cybersecurity Programs for Bank of Israel Directives
- Compliance Program for the Office of the Comptroller of the Currency’s Heightened Standards for Large Financial Institutions, 2013
- Compliance Program for the Dodd-Frank Act’s Volker Rule, 2014
- Corporate Investigations, various, including suspicions of bribery, official corruption, illegal gambling, lax counter-terrorist financing, improper competitive practices, securities manipulation and financial fraud
PUBLICATIONS AND PRESENTATIONS
- Host, Opinions My Own: Risk, FinTech & the Law, Podcast, 2021 - Present
- Speaker, Expert Networks – Regulatory Risk Management & Sound China Practices, Morgan Stanley, Hong Kong, November 2023
- Author, Geopolitical Risk and Operating Effectively In Light of China’s Expanded Anti-Espionage Law, Third Bridge Group, November, 2023
- Moderator, The State of Regulation & Enforcement in China, Third Bridge Group, Shanghai, China April 2023
- Host, Behaving Ethically: A Conversation with Justin Papery, Fordham Law School and Third Bridge Group, Los Angeles, CA, December 2022
- Speaker, Managing Risk & Compliance in Expert Networks, with Kapil Kirpalani, KKR CCO, The Signal podcast, Mumbai, India, August 2022
- Host, Opinions My Own: AML, FinTech & the Law, Podcast, Apple, YouTube, Fall 2021
- Lecturer, Deconstructing the Aftermath: Lessons Learned from HSBC’s $2Bn AML Fine, various: New York, NY, 2019 – 2022; Tel Aviv, Israel, 2015 – 2019
- Speaker, Model Risk Management for Boards of Directors, IDB Bank, New York, NY, June 2021
- Speaker, CFPB for Boards of Directors: Supervision, Examinations, Enforcements and Consumer Complaints, IDB Bank, New York, NY, June 2021
- Moderator, FinCEN Files: The New Panama Papers?, Fordham Law School, New York, NY, November 2020
- Moderator, Privileged Access Management, with CyberArk CEO, New York Institute of Technology, New York, NY, July 2019
- Speaker, Effective Cybersecurity Training, Cybercrime Magazine, Northport, NY, June 2019
- Panelist, Vendor Risk Management through the Lens of GDPR, e-Privacy & State Privacy Protections, Global Financial Markets Intelligence Conference, New York, NY, February 2019
- Panelist, Ensuring Compliance with NYSDFS Rule 500, Cybersecure, New York, NY, December 2017
- Panelist, ID, KYC and AML Within an Increasingly Demanding Regulatory Framework, ECN Identity & KYC Summit, New York, NY, November 2017
- Panelist, Rethinking Identity Authentication to Enhance KYC and AML, ECN Identity & KYC Summit, New York, NY, November 2016
- Lecturer, Compliance Landscape Facing Commercial Banking, Citi Credit College, New York, NY, various, 2013 – 2014
- Speaker, UIGEA and Online Payments, Global i-Gaming Seminar & Expo, San Francisco, CA, April 2012
- Panelist: The Reemergence of the FCPA, Thomson Reuters’ Governance, Risk & Compliance Forum, New York, NY, June 2011
- Speaker: The UIGEA Landscape Facing Financial Institutions, Global i-Gaming Seminar & Expo, San Francisco, CA, May 2011
- Lecturer, Ethical Investigations in the Wake of Hewlett-Packard, Fairfield University, Fairfield, CT, March 2007
- Author, The Impending End & New Beginning, Inside Lacrosse Magazine, January 2007
- Author, The Right to Confrontation & the Improbability of Conviction, Inside Lacrosse Magazine, December 2006
- Author, Why Reade Seligmann Won’t Face Trial, Inside Lacrosse Magazine, October 2006
- Author, Trial by Media & the Duke Defense Attorneys, Inside Lacrosse Magazine, June 2006
LANGUAGES
