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Thomas C. Baxter Jr.

Of Counsel

Thomas C. Baxter Jr.

Of Counsel
New York +1-212-558-4000+1-212-558-4000 +1-212-558-3588+1-212-558-3588
[email protected]
As a member of the Firm’s Financial Services Group, Thomas C. Baxter, Jr. focuses his practice on advising clients in the financial services, insurance, securities and FinTech spaces. Mr. Baxter’s advice relates to complex issues arising from supervision and regulation, investigations and enforcement actions, governance, compliance and risk management, crisis management and organizational culture. He also brings extensive experience dealing with central banks from around the world, and with sovereigns and their instrumentalities, as they address sovereign debt and dollar-liquidity issues. Mr. Baxter’s deep knowledge in these areas comes from more than 35 years at the Federal Reserve Bank of New York, most in senior leadership roles.

Prior to joining Sullivan & Cromwell, Mr. Baxter was General Counsel and Executive Vice President of the Federal Reserve Bank of New York. While serving for more than 20 years in that senior official position, Mr. Baxter led the New York Fed’s Legal Group. In addition to nearly 50 lawyers providing legal services, the Legal Group has significant non-legal functions, including the law enforcement unit, the corporate secretary’s office, the compliance and ethics function and the banking applications function. Mr. Baxter also served on the Management Committee, the bank’s highest-level executive committee.

In his capacity as General Counsel and Executive Vice President, Mr. Baxter was one of the primary designers of the historic liquidity programs developed by the Federal Reserve during the 2008 financial crisis. He was also a leading legal architect of the AIG and Bear Stearns rescues. Prior to that, he spearheaded the Federal Reserve’s on-the-ground efforts, following the September 11 terrorist attacks, to provide liquidity to financial markets and to assist New York City in its recovery.

Earlier in his career at the Fed, Mr. Baxter served as deputy general counsel for enforcement, where he led the Federal Reserve’s enforcement response to BCCI—the Bank of Credit and Commerce International. BCCI was, and remains, the largest bank fraud in history. Mr. Baxter’s handling of the BCCI case drew praise from then-Fed chairman Alan Greenspan, who called Mr. Baxter “instrumental” in “initiating” this case, and also in “bringing it to a conclusion.”

Mr. Baxter joined the bank in 1980, following a one-year appointment as a law assistant to the justices of the Appellate Division of the New York State Supreme Court.

Other Professional Activities and Recognitions
Mr. Baxter is active in the legal community as a member of the American Bar Association and the International Law Association. He is a Member of the American Law Institute, and has been recognized for his work in the legal community including:
  • Being appointed to P.R.I.M.E. Finance Foundation’s Panel of Experts
  • Being cited as one of The American Lawyer’s Dealmakers of the Year
  • Receiving an award from the Lawyers Alliance for his work in starting the Lawyers Foreclosure Intervention Network
  • Receiving an award from the Association of Corporate Counsel for an innovative educational program about legal ethics
  • Being appointed Business Law Advisor to the Business Law Section of the American Bar Association
Writing and Speaking
Mr. Baxter has published numerous articles about the legal aspects of bank supervision, check collection, securities transfers, electronic transfers of funds and the financial services industry. He also is a joint author and author of several publications, including:
  • “The Interrelationship of Article 4A With Other Law” (The Business Lawyer, 1990)
  • “Commercial Paper, Bank Deposits and Collections, and Other Payment Systems” (The Business Lawyer, 1990)
  • “Article 4A: The New Law of Funds Transfers and The Role of Counsel” (UCC Law Journal, 1991)
  • “Wire Transfers: A Guide to U.S. & Int’l Laws Governing Funds Transfers” (Bankers Pub. Co., 1993)
  • “The UCC Thrives In The Law of Commercial Payment” (Loyola of Los Angeles Law Review, 1994)
  • “Resolving Funds Transfer Disputes Related to Currency Exchange Transactions: What Law Governs?” (Commercial Law Annual 297, 1995)
Mr. Baxter is a frequent lecturer at programs sponsored by the Uniform Commercial Code Institute, the Department of Justice’s Advocacy Institute, the American Bar Association, the American Law Institute, the Bank Administration Institute, the Practising Law Institute, the Federal Financial Institutions Examination Council and similar organizations.