Thomas C. Bogle

Thomas-Bogle

Thomas C. Bogle

Partner

Washington, D.C. | 1900 K Street, NW, Washington, DC, United States of America 20006-1110
+1 202 261 3360 | +1 202 261 3333

| vCard | PDF

Thomas C. Bogle advises financial services companies on a wide range of corporate, regulatory and enforcement matters. His clients include U.S. registered funds and their boards of directors, investment management firms, banks, broker-dealers and insurance companies. Mr. Bogle has particular experience advising registered funds, independent directors and investment advisers on the full range of issues under the federal securities laws, including the Investment Company Act of 1940, the Investment Advisers Act of 1940 and the provisions of the Dodd-Frank Act applicable to asset managers.

Mr. Bogle is actively engaged in the firm’s anti-money laundering and sanctions compliance practice. He regularly counsels U.S. and non-U.S. corporations, financial institutions and financial industry trade associations on matters relating to the Bank Secrecy Act and U.S. economic and trade sanctions administered by OFAC.

Mr. Bogle has been recognized in The Legal 500 (US) in the area of mutual/registered funds. Since 2014, he has been listed annually in The Best Lawyers in America for mutual funds law. He has also been named as a “Rising Star” for Investment Funds by Euromoney/Legal Media Group in its Expert Guides series and as one of Fund Action’s Rising Stars of 2014.

Mr. Bogle serves as a member of the firm’s Washington office pro bono committee and as a leader of its non-profit and small business pro bono practice group. He is a member of the board of directors of Friends of New Orleans, Inc., and serves on the board of advisory editors of the Tulane Law Review.

Prior to attending law school, Mr. Bogle worked on Capitol Hill and for federal political campaign committees.

Education
  • The George Washington University, B.A., cum laude
  • Tulane University Law School, J.D., magna cum laude, senior board of the Tulane Law Review, Order of the Coif
Admissions
  • New York
  • District of Columbia
Speaking Engagements
  • Academic and Practitioner Symposium on Mutual Funds and ETFS —  Presented by the Investment Company Institute and the University of Virginia Darden School of Business' Richard A. Mayo Center for Asset Management, Arlington, VA (February 21-22, 2019)

Speaker, ESG Paper Discussion of " Coordinated Engagements" by Elroy Dimson, Oğuzhan Karakaş, and Xi Li.

  • Liquidity Risk Management and Data Reporting: Director Responsibilities Under the New SEC Rules — IDC Session at the Investment Company Institute's General Membership Meeting, Washington, D.C. (May 3-5, 2017)

Speaker, “Liquidity Risk Management and Data Reporting: Director Responsibilities Under the New SEC Rules.” panel discussed the current status of funds’ implementation of the liquidity risk management and data reporting rules and the new responsibilities boards will have under the rules.

  • An AML Blueprint: Tighten Controls and Satisfy FinCEN — IA Compliance: The Full 360° View –Compliance Solutions for a Rapidly Changing Regulatory World, Washington, D.C. (April 5-7, 2017)

Speaker, “An AML Blueprint: Tighten Controls and Satisfy FinCEN” panel examined AML programs and will offer ideas for how investment advisers can create such programs.

  • The SEC's New Fund Reporting and Liquidity Rules: What Do They Mean for the Fund Industry? — Presented by the Investment Company Institute, Boston (November 17, 2016)

Speaker, “Overview: How Has the SEC Transformed Fund Reporting and Liquidity Risk Management?” panel.

  • IA Compliance: The Full 360° View —Presented by IA Watch, Washington, DC (February 25, 2016)

Speaker, "Achieving AML Success in Light of FinCEN’s Coming Mandate" panel. 

  • Preparing for the Future of Global Customer Due Diligence — ACAMS money laundering.com International AML & Financial Crime Conference, Hollywood, FL (March 18, 2015)

Speaker, "Preparing for the Future of Global Customer Due Diligence" panel discussion topics included: Clarifying the definition of beneficial ownership under FinCEN’s proposed new rules; Comparing new customer due diligence standards to your existing program; and Assessing the FATF’s role in establishing a single standard for customer due diligence.

  • The Regulatory Outlook for Funds and Advisers: Domestic and Foreign Priorities — ICI Mutual Funds and Investment Management Conference, Palm Desert, CA (March 15, 2015)

Speaker, "The Regulatory Outlook for Funds and Advisers: Domestic and Foreign Priorities" panel. 

  • SIFMA's Anti-Money Laundering and Financial Crimes Conference — New York, NY (February 25, 2015)

Speaker, "SIFMA's Anti-Money Laundering and Financial Crimes Conference" panel oncustomer due diligence challenges in the context of the FinCEN proposal and how best to tailor compliance priorities.

  • Exploring the Latest Regulatory and Litigation Trends affecting Variable Products and Underlying Funds — Insured Retirement Institute's 2014 Government, Legal & Regulatory Conference, Washington, D.C. (June 29, 2014)

Speaker, “Exploring the Latest Regulatory and Litigation Trends affecting Variable Products and Underlying Funds” panel discussed how important regulatory initiatives at the SEC and FINRA affect the industry in 2014 and beyond.

  • Off the Beaten Path: How to Avoid Missteps When Investing in Emerging and Frontier Markets — ICI Mutual Funds and Investment Management Conference, Orlando, FL (March 17, 2014)

Speaker, "Off the Beaten Path: How to Avoid Missteps when Investing in Emerging and Frontier Markets" panel.

  • Legal Forum: Compliance with Anti-Corruption Laws and Economic Sanctions — Investment Company Institute General Membership Meeting, Washington, D.C. (May 1, 2013)

Speaker, "Compliance with Anticorruption Laws (FCPA and International Equivalents) and Economic Sanctions" panel discussion topics included: recent enforcement trends in anti-bribery; economic sanctions compliance; lessons learned about the importance of establishing a compliance culture; testing for compliance; properly handling internal investigations; and disclosures to government authorities. 

  • Managing Anti-Money Laundering Risk: Best Practices and Effective Tools — National Regulatory Services 26th Annual Fall Investment Adviser and Broker-Dealer Compliance Conference, Las Vegas, NV (October 26, 2011)
  • Anti-Money Laundering Developments and Trends — 2011 Anti-Money Laundering Discussion Forum Conference Presented by Invesco, Houston, Texas (October 20, 2011)
  • Hot Topics: Anti-Corruption and Business Ethics — Investment Company Institute and Federal Bar Association 2011 Mutual Funds and Investment Management Conference, Palm Desert, CA (March 27, 2011)
  • Anti-Money Laundering: The Specific Duties of Transfer Agents — The STA Annual Conference, Naples, FL (October 23, 2007)
  • “Knowing Your Customer -Your Questions Answered” and “Suspicious Activity Reporting” — 2005 Anti-Money Laundering Workshop, Boston, MA (February 24, 2005)
  • Anti-Money Laundering Issues in the United States — Caribbean American Leadership Dialogue, Washington, DC (November 15, 2002)
  • Anti-Money Laundering Regulatory Developments in the Investment Management Industry — Investment Companies Committee of the Philadelphia Bar Association, Philadelphia, PA (November 13, 2002)