Charles C. Gray is a partner in the Firm’s Financial Services Group. He focuses on advising financial services clients on a wide variety of bank regulatory, supervisory and enforcement matters. With fifteen years of experience at the Federal Reserve and Treasury Department, Mr. Gray is a knowledgeable adviser and frequent speaker on bank regulatory law and policy, including in the areas of resolution planning, capital, liquidity and cross-border supervision of international financial firms.
Government Service
Prior to rejoining the Firm in September 2024, Mr. Gray was Deputy General Counsel of the Federal Reserve Board, serving as head of the Financial Regulation and Policy Group within the Board’s Legal Division. In this role, Charles oversaw a large legal team spanning both the Banking Regulation and Policy Group and the Monetary Affairs and Payment Systems Group, with responsibility for providing legal and policy advice across the full range of complex rulemaking, interpretive, and applications matters arising in those areas. Mr. Gray also served as Assistant General Counsel of the Federal Open Market Committee.
In March 2020, Mr. Gray left Sullivan & Cromwell to join the Board of Governors to help lead the array of emergency lending programs that were put into place by the Federal Reserve and the U.S. Department of the Treasury to in response to the economic disruption brought about by the COVID-19 pandemic. For these efforts (on detail to the Treasury Department) he received the Treasury Department’s Distinguished Service Award.
Mr. Gray’s COVID crisis work drew on his prior career experience as a senior officer at the Federal Reserve Bank of New York, where he served from 2006-2016 during a historic period of financial crisis and post-crisis financial reform. As a member of the New York Fed’s Legal Group, Mr. Gray helped to shape and carry out the Fed’s response to the 2008 financial crisis. In 2010, Mr. Gray served as a policy adviser to the U.S. Department of the Treasury, where he contributed to the drafting and development of the Dodd-Frank Act. He then participated in a broad range of regulatory and supervisory efforts to implement the legislation and to develop related post-crisis international standards.
Earlier in his career at the Fed, Mr. Gray was active as an Enforcement Attorney on a number of large public enforcement cases dealing with violations of Bank Secrecy Act / Anti-Money Laundering and Office of Foreign Assets Control regulations, as well as cases involving trading misconduct and consumer violations.
Prior to law school Mr. Gray served as a Professional Staff Member for the Banking and Financial Services Committee of the U.S. House of Representatives, where he worked for Chairman Jim Leach on the legislation ultimately enacted as the Gramm-Leach-Bliley Act of 1999. Following a judicial clerkship, Mr. Gray began his legal practice as an associate in Sullivan & Cromwell's Financial Services Group from 2003 to 2006 and returned as special counsel from 2016 to 2020.
