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PAUL TYRRELL is a leading adviser to the financial services industry on significant compliance and regulatory matters affecting the broad base of industry participants (bulge bracket firms, fund companies/distributors, and large independent broker-dealers). Paul’s practice involves managing high-profile regulatory investigations before the U.S. Securities and Exchange Commission, FINRA, the U.S. Commodity Futures Trading Commission, the National Futures Association, state securities regulators, and exchanges.
Paul routinely manages investigations and enforcement matters involving complex systemic issues, supervision, and sales practice violations. He counsels financial services firms on myriad rules and regulations across all aspects of their financial services business lines. With industry-leading experience related to anti-money laundering (AML) program compliance and enforcement, Paul has managed significant broker-dealer AML regulatory matters throughout his career. Paul serves clients across platforms to provide practical advice and insight into the complexities of enterprise-wide compliance (cross-discipline/business lines), reinforced from his years of experience as a former regulator at FINRA, the CFTC, and FDIC.
Paul is a member of Sidley’s Securities Enforcement and Regulatory group, which received the 2019 Chambers USA award for “Financial Services Regulation,” and was named “Law Firm of the Year” for Securities Regulation in 2020 and 2017 by U.S. News — Best Lawyers. Given Paul’s breadth of experience in financial services regulation, he is a frequent speaker at national conferences. Paul has been recognized by The Best Lawyers in America® in Financial Services Regulation Law (2026).
Prior to joining Sidley, Paul was a senior special regional counsel at FINRA’s (formerly NASD) Boston District Office. He managed investigations and filed disciplinary matters arising out of broker-dealer examinations. He also counseled Member Regulation staff and industry participants on FINRA and MSRB rules.
He served as a senior trial attorney with the CFTC in New York, where he managed enforcement matters involving commodity futures and options. He also worked as a senior attorney with the FDIC and taught business law at the University of Massachusetts-Boston.
コミュニティへの参加
Membership & Activities
- Member, Florida Securities Dealers Association, Inc. (FSDA)
- Member, Financial Services Committee and Civil Enforcement Committee, Boston Bar Association
資格
弁護士資格・登録
- U.S. Court of Appeals, 1st Circuit
- U.S. Court of Appeals, D.C. Circuit
- U.S. District Court, District of Connecticut
- U.S. District Court, District of Massachusetts
- District of Columbia
- Massachusetts
学歴
- Western New England University School of Law, 法務博士, 1990
- University of Florida, B.A., 1986
得意分野
ニュース＆インサイト
Federal Agencies Propose More GENIUS AML/CFT Rules: Customer Identification Program and OCC Conforming UpdatesJune 25, 2026SEC Rescinds Its Gag Rule PolicyMay 19, 2026New U.S. SEC Enforcement Director David Woodcock Signals Continued “Back to Basics” ApproachMay 14, 2026FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin IssuersApril 22, 2026
White Collar Watch
White Collar Watch
White Collar Watch
White Collar Watch
- Co-author, “FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin Issuers,” Sidley Update, April 20, 2026.
- Co-author, “Chief Compliance Officer Discipline Remains on FINRA’s Radar,” Sidley Update, February 3, 2026.
- Co-author, "FINRA Issues 2026 Regulatory Oversight Report," Sidley Update, December 16, 2025.
- Co-author, “FinCEN Postpones Effective Date of Anti-Money-Laundering Rule for Investment Advisers and Exempt Reporting Advisers,” Sidley Update, July 21, 2025.
- Co-author, “FINRA Seeks Public Comment on Efforts to Modernize Member Workplace Rules,” Sidley Update, April 22, 2025.
- Co-author, “U.S. Treasury will not Enforce Corporate Transparency Act Against U.S. Citizens or Domestic Companies or Their Beneficial Owners,” Sidley Update, March 4, 2025.
- Co-author, “With New Technologies Come New Risks: FINRA Issues 2025 Regulatory Oversight Report,” Sidley Update, February 4, 2025.
- Author, “Investment Advisers Begin Critical Year of AML Compliance Planning,” Corporate Compliance Insights, January 14, 2025.
- Co-author, “Another Corporate Transparency Act Surprise: Filing Obligations Suspended Again,” Sidley Update, December 31, 2024.
- Co-author, “Corporate Transparency Act Reporting Obligations Reinstated with Extensions—Earliest Filing Deadline Now January 13, 2025,” Sidley Update, December 26, 2024.
- Co-author, “Texas Federal Court Issues Preliminary Injunction Against Corporate Transparency Act,” Sidley Update, December 5, 2024.
- Co-author, “D.C. Circuit Enjoins FINRA from Expelling Member Before SEC Review,” Sidley Update, November 26, 2024.
- Co-author, “FinCEN Issues Proposed Rule to Modernize Anti-Money-Laundering/Financing of Terrorism Programs Under Bank Secrecy Act,” Sidley Update, July 8, 2024; Republished by The Banking Law Journal, October 2024.
- Co-author, “SEC and FinCEN Propose Customer Identification Program Rule for Registered Investment Advisers and Exempt Reporting Advisers,” Sidley Update, May 15, 2024.
- Co-author, “IT’S BA-ACK: FinCEN Issues Notice of Proposed Rulemaking for SEC Registered Investment Advisers and SEC Exempt Reporting Advisers,” Sidley Update, February 14, 2024.
- Co-author, “It Appears Everything Is a Risk: FINRA Issues 90-page 2024 Regulatory Oversight Report,” Sidley Update, January 29, 2024.
- Co-author, “Long-Awaited Guidance on New Rules Regarding Residential Supervisory Locations and Remote Branch Office Inspections,” Sidley Update, January 25, 2024.
- Co-author, Fifth Circuit Vacates U.S. Commodity Futures Trading Commission’s $6.5 Million Jury Verdict for Lack of Fair Notice,” Sidley Update, January 22, 2024.
- Co-author, “CFTC Issues Proposed Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts,” Sidley Update, December 11, 2023.
- Co-author, “U.S. SEC Division of Exams Announces 2024 Examination Priorities,” Sidley Update, October 26, 2023.
- Co-author, “U.S. CFTC Sends a Message: Higher Penalties, More Monitors and Consultants, and Fewer No-Admit/No-Deny Resolutions,” Sidley Update, October 24, 2023.
- Co-author, “U.S. SEC Division of Examinations Risk Alert Focuses on Broker-Dealers Anti-Money Laundering Program Compliance,” Sidley Update, August 2, 2023.
- Co-author, “Cybersecurity and Environmental Fraud Top Priorities of U.S. Commodity Futures Trading Commission Division of Enforcement,” Sidley Update, July 12, 2023.
- Co-author, “D.C. Circuit Questions Constitutionality of FINRA Hearing Officers, Enjoins Disciplinary Proceeding,” Sidley Update, July 6, 2023.
- Co-author, “FINRA Issues Regulatory Notice on Broker-Dealer Responsibilities in Private Placements,” Sidley Update, May 18, 2023.
- Co-author, “FINRA Issues 2023 Report on Its Examination and Risk Monitoring Program,” Sidley Update, January 30, 2023.
- Co-author, “FINRA Issues Revised Sanction Guidelines,” Sidley Update, October 3, 2022.
- Co-author, “FINRA Issues 2022 Report on Its Examination and Risk Monitoring Program,” Sidley Update, March 2, 2022.
- Co-author, “SEC Announces Long-Awaited Updates to Broker-Dealer Recordkeeping Requirements,” Sidley Update, December 20, 2021.
- Co-author, “FinCEN Issues Government-Wide Priorities for Anti-Money Laundering and Counter-Terrorist Financing,” Sidley Update, July 1, 2021.
- Co-author, “FinCEN Seeks Public Comments on Beneficial Owner Reporting Requirements,” Sidley Update, April 5, 2021.
- Co-author, “Corporate Transparency Act: New Federal Reporting Requirements for Certain U.S. Formed or Registered Entities,” Sidley Update, February 17, 2021.
- Co-author, “Congress Rings in the New Year With Substantial Changes to Anti-Money Laundering Laws,” Sidley Update, January 5, 2021.
- Co-author, “FinCEN Identifies Key Factors in Evaluating Potential or Actual BSA Violations for Enforcement Actions,” Sidley Update, August 21, 2020.
- Co-author, “FinCEN Issues Guidance to Financial Institutions With Hemp-Related Business Customers,” Sidley Update, July 6, 2020.
- Co-author, “Financial Crimes Enforcement Network Requests Comment on Burden Imposed on Financial Institutions Related to Filings,” Sidley Update, May 26, 2020.
- Co-author, “FinCEN Issues Notice on Reporting COVID-19 Criminal and Suspicious Activities, Companion Advisory on COVID-19-Related Medical Scams,” Sidley Update, May 21, 2020.
- Co-author, “FINRA Issues New Anti-Money Laundering Red Flag Guidance For Broker-Dealers,” Sidley Update, May 8, 2019.
- Co-author, “First Criminal Charge of U.S. Broker-Dealer for Bank Secrecy Act Violation Highlights Importance of Anti-Money-Laundering Controls,” Thomson Reuters, January 11, 2019.
- “Why CCOs Should Check CIPs For Institutional Accounts,” Compliance Intelligence, March 5, 2014.
- “Recent AML Enforcement Cases,” The Review of Securities & Commodities Regulation, Vol. 46 No.18, October 16, 2011.
- Co-author, “Groundbreaking Proposal by MSRB Relating to Municipal Securities Underwriters' Obligations to State and Local Government Clients,” Securities Litigation Commentator, September 2011.
- Co-author, “FinCen Clarifies Suspicious Activity Report (“SAR”) Confidentiality and Expands SAR Sharing to Certain Affiliates,” Journal of Investment Compliance, March 2011.
- Co-author, “FINRA Proposes to Require Registration of Back Office and Operations Personnel,”Journal of Investment Compliance, Vol. 11 No. 3, 2010.
- Co-author, “FinCEN Issues Joint Release Providing Guidance on Obtaining and Retaining Beneficial Ownership Information,” Financial Fraud Law Report, Vol. 2 No. 5, May 2010.
- Co-author, “FinCEN Expands Access to section 314(a) Information Requests,” Privacy & Data Security Law Journal, Vol. 5, No. 2, February 2010.
- “A Chilling Effect: The Impact of the Motion to Dismiss under the Private Securities Litigation Reform Act of 1995,” Federal Rules Decisions, 173 F.R.D. 556, October 1997.
- “Piercing the Judicial Veil,” The Army Lawyer, April 1989.
- Speaker, “2A Workshop: Effective Board Reporting and Engagement,” SIFMA AML Conference 2026, New York City, NY, June 4, 2026.
- Moderator, “Ask FINRA,” SIFMA Compliance and Legal Society Annual Seminar, Orlando, FL, March 24, 2026.
- Speaker, “AML Reform,” SIFMA GC CCO Roundtable. Chicago, IL, September 18, 2025.
- Speaker, “Compliance Challenges,” SIFMA GC CCO Roundtable. Chicago, IL, September 18, 2025.
- Moderator, “So You Want to Be a COO,” SIFMA C&L Regional Southeast Conference, Charlotte, NC, September 9, 2025.
- Speaker, “Hot Topics in AML Program Governance,” SIFMA AML Conference, May 13, 2025.
- Speaker, “Regulatory Exams and Interacting with Regulators,” The National Society of Compliance Professionals (NSCP) webinar, May 22, 2024.
- Speaker, “Implementing the AML Act and CTA,” SIFMA AML Conference, May 6, 2024.
- Speaker, “Anti-Bribery and Sanctions,” SIFMA Compliance and Legal Society Annual Seminar, Orlando, FL, March 19, 2024.
- Speaker, “Cooperation and Self-Reporting to Regulators,” SIFMA General Counsel Roundtable, Chicago, IL, October 23, 2023.
- Speaker, “CFTC Enforcement of Environmental Fraud,” Futures Industry Association Webinar, October 12, 2023.
- Speaker, “Current Issues in AML and Economic Sanctions,” SIFMA C&L Society Charlotte Regional Seminar, Charlotte, NC, September 11, 2023.
- Speaker, “Regulatory/Enforcement Developments and 2023 Priorities,” SIFMA's Anti-Money Laundering & Financial Crimes Conference, May 22, 2023.
- Moderator, “Perspectives on Supervision: A Conversation with Chief Supervisory Officers,” SIFMA C&L Society Charlotte Regional Seminar, Charlotte, NC, September 19, 2022.
- Speaker, “Best Practices on Identifying SEC Associated Persons of U.S. Broker Dealers,” Association of Registration Management, Inc.’s 2022 Annual Educational Conference, June 2022.
- Speaker, “Emerging Risk Management - Assessing New Product and Services,” SIFMA Anti-Money Laundering & Financial Crimes Annual Conference, May 2022.
- Speaker, “Hedge Funds, Private Equity and Advisors: Managing Risk without Regulation,” SIFMA Anti-Money Laundering & Financial Crimes Annual Conference, February 2021.
- Speaker, “Hot Topics in Fintech AML,” Sidley Austin LLP, November 2, 2020.
- Moderator, “Virtual Branch Office Compliance Visits,” SIFMA Webinar Series, October 5, 2020.
- Speaker, “Pandemic Stimulus Packages — Navigating Risk While Preparing for Inquiries and Investigations,” Sidley Austin LLP, June 8, 2020.
- Speaker, “Navigating Increased Regulatory Scrutiny on Your Institution’s Wealth Management Business,” 2020 Annual BISA (Bank Insurance & Securities Association) Conference, Hollywood, FL, March 5, 2020.
- Speaker, “Regulatory and Enforcement Trends 2020,” Anti-Money Laundering & Financial Crimes Conference, New York, NY, February 5, 2020.
- Speaker, “Hot Topics in AML and OFAC Compliance,” SIFMA C&L Society Charlotte Regional Seminar, Charlotte, NC, September 23, 2019.
- Speaker, “Reviewing Recent Enforcement Actions and Regulatory Actions to Manage AML Risks,” FINRA Annual Conference, Washington, D.C., May 16, 2019.
- Speaker, “Anti-Money Laundering – The Evolution of Technology in AML Review,” Compliance and Regulation, Sidley Austin LLP, New York, NY, October 17, 2018.
- Speaker, “Anti-Money Laundering – Customer Identification Programs and Customer Due Diligence Best Practices,” Financial Services Compliance Boot Camp at the Center for Finance and Banking at the University of North Carolina School of Law, June 2018.
- Speaker, “Lessons Learned from Recent AML Enforcement Actions,” FINRA Annual Conference, Washington, D.C., May 21, 2018.
- Speaker, “Anti-Fraud Framework,” SIFMA Compliance and Legal Society Annual Seminar, Orlando, FL, March 21, 2018.
- Speaker, SIFMA General Counsel Roundtable, February 9, 2018.
- Speaker, “AML/OFAC Sanctions Update,” SIFMA Compliance and Legal Society Charlotte Seminar, Charlotte, NC, September 18, 2017.
- Speaker, “Building the Fifth Pillar: Customer Due Diligence and Beneficial Ownership Requirements for Financial Institutions,” Sidley Austin LLP, New York, NY, May 9, 2017.
- Speaker, “Personal Liability for Compliance Officers: How to Protect Yourself,” SIFMA Compliance and Legal Society Annual Seminar, San Diego, CA, March 22, 2017.
- Speaker, “AML/OFAC Sanctions Requirements and Compliance to Legal Professionals,” Boston Bar Association, Boston, MA, January 26, 2017.
- Speaker, “Boston Compliance Officer Roundtable Series,” Sidley Austin LLP, Boston, MA, October 14, 2016.
- Speaker, “Reducing Your Liability in Compliance With FINRA,” Lorman Education Services, September 2016.
- Speaker, “Financial Crimes—Anti-Money Laundering,” University of North Carolina School of Law: Center for Banking and Finance, Charlotte, NC, August 17, 2016.
- Speaker, “Current Anti-Money Laundering Topics: Beneficial Ownership and Investment Adviser Proposed AML Program Rules,” Boston Bar Association CLE Program, Boston, MA, May 24, 2016.
- Speaker, “Enforcement Trends and Takeaways,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, NY, April 6, 2016.
- Speaker, “Investment Adviser Anti-Money Laundering Obligations Under FinCEN Rule Proposal,” Goldman Sachs 12th Annual Boston Hedge Fund Conference, Boston, MA, March 10, 2016.
- Speaker, “Investment Adviser Anti-Money Laundering Obligations Under FinCEN Rule Proposal,” Goldman Sachs 2nd Annual Prime Services General Counsel Conference, New York, NY, February 25, 2016.
- Speaker, “Ever Expanding Expectations of AML Programs,” FMA Compliance & Legal Society, Denver Regional Seminar, Denver, CO, January 28, 2016.
- Speaker, Sidley Austin LLP Boston Compliance Officer Roundtable Series, Boston, MA, November 2015.
- Speaker, “Unclaimed Property Audits and Compliance Challenges for the Broker-Dealer and Securities Industry,” Sidley Austin LLP Webinar, June 16, 2015.
- Speaker, “Registration Updates Related to Municipal Securities and Swaps,” Association of Registration Managers Conference, March 2015.
- Speaker, “Lessons Learned From Recent AML Enforcement Actions,” SIFMA Anti-Money Laundering and Financial Crimes Conferences, New York, NY, January 30, 2014.
- Speaker, “Unclaimed Property: Key Issues for Broker-Dealers,” Webinar, October 2013.
- Speaker, “Anti-Money Laundering Updates for Investment Advisers and Private Funds,” National Society Of Compliance Professionals National Conference, Washington, D.C., October 2013.
- Speaker, “NFA/CFTC Enforcement,” Boston Bar Association Commodity Regulatory Roundtable, Boston, MA, October 2013.
- Speaker, “Regulatory/Legislative Landscape,” Compliance Solutions Regional Roundtable, Boston, MA, September 2013.
- Speaker, “Recent Regulatory Investigation & Enforcement Trends,” SIFMA Compliance and Legal Society San Francisco Regional Seminar, August 2013.
- Speaker, “New Compliance Obligations Facing Swap Dealers,” Introducing Brokers and Futures Commission Merchants, New York, NY, March 2013.
- Speaker, “Key Compliance Issues for Registered Commodity Pool Operators and Commodity Trading Advisors,” New York, NY, March 2013.
- Speaker, “Ethics Are Important — But How Do I make It Practical?” NSCP 2013 New England Regional Meeting, Boston, MA, March 2013.
- Speaker, “AML for Broker Dealers,” National Society of Compliance Professionals' National Membership Meeting, Washington, D.C., October 2012.
- Speaker, “FINRA’s New Rules on Communications with the Public: Guidance and Compliance Best Practices,” BD Week Webinar, October 2012.
- Speaker, “Anti-Money Laundering Requirements Under the Bank Secrecy Act,” Lorman Webinar, July 2012.
- Moderator, “Annual Certifications Lab,” NSCP New England Regional Lab, Boston, MA, April 2012.
- Speaker, “Update from the Regulators: Developments and Priorities for FINRA Enforcement,” Boston Bar Association — Securities Enforcement and Litigation Committee, Boston, MA, February 2012.
- Speaker, “Outside Business Activities: What Regulators Are Looking At and Ways to Keep Track of What Your Reps Are Doing,” Broker-Dealer Week Webinar, Boston, MA, November 2011.
- Speaker, “Do I Really Have to Do This?” NAIBD Fall Symposium: Providing Business and Development Tools for Independent Broker-Dealers, New York, NY, November 2011.
- Speaker, “Social Media — The Devil Is in the Details,” Boston Broker-Dealer Investment Advisers’ LinkedIn Group Mixer, Boston, MA, November 2011.
- Speaker, “Due Diligence in a Global Economy: Money Laundering Concerns for Broker-Dealers,” New York, NY, October 2011.
- Speaker, “Defending Broker-Dealers Before FINRA,” FINRA’s Regional Enforcement Meeting, Boston, MA, April 2011.
- Speaker, “Anti-Money Laundering Requirements Under the Bank Secrecy Act,” Lorman Webinar, February 2011.
- Speaker, “Recent Anti-Money Laundering Enforcement Actions,” SIFMA Anti-Money Laundering and Financial Crimes Conference, March 2010.
- Speaker, “Broker-Dealer Enforcement Clinic,” Connecticut Department of Banking Securities Forum, October 2007.
- Speaker, “State Regulation and Broker-Dealer Regulation,” ALI-ABA, January 2005.
- Speaker, “Variable Annuities,” Connecticut Department of Banking Securities Forum, October 2002.
- Speaker for various NASD outreach programs to broker-dealer community.