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A member of the international arbitration and financial institutions practices, Nikhil V. Gore represents sovereign states and U.S. and global firms in international treaty-based and commercial disputes. He also regularly represents U.S. financial institutions, and the U.S. branches and affiliates of foreign financial institutions, in investigations and inquiries involving the Federal Reserve, OCC, FDIC, CFPB, and state banking regulators.
Mr. Gore has served as counsel in investment and commercial arbitrations spanning several industries and a variety of regions, including Asia, Eastern Europe, North America, and Southern Africa. Additionally, he has expertise in the law of the sea, and was part of the Covington team that secured an order from the International Tribunal for the Law of the Sea, which required Russia to release three Ukrainian naval vessels and twenty-four servicemen detained in the Black Sea in 2018.
In his financial institutions practice, Mr. Gore has experience with enforcement actions and investigations relating to the Bank Secrecy Act, the federal criminal money laundering statutes, the full range of safety and soundness issues (including, in particular, supervisory reviews of bank control functions), and fair lending and consumer compliance. Mr. Gore is a regular contributor to the firm’s financial services blog.
Financial Institutions
- Regular representations of local, regional, and national U.S. financial institutions in responding to bank regulatory inquiries and enforcement actions.
- Representation of a global financial institution in connection with alleged violations of the Bank Secrecy Act and corresponding laws in other jurisdictions.
- Representation of a global financial institution in connection with a significant, multi-jurisdictional investigation of alleged money laundering, foreign corruption, and related issues.
- Representation of financial industry trade associations as amici curiae in cases before U.S. District Courts and Courts of Appeal.
- Representation of a bank in an intra-agency appeal of a supervisory determination.
International Arbitration
- Counsel to Ukraine in Case Concerning the Detention of Three Ukrainian Naval Vessels (Provisional Measures), ITLOS Case No. 26.
- Representation of a large electronics company in a commercial dispute with a vendor.
- Representation of a major pharmaceutical company in an investment arbitration.
- Representation of a large property developer in connection with an investment dispute.
- Counsel and Advocate for Ukraine in an arbitration against the Russian Federation under the U.N. Convention on the Law of the Sea.
- Representation of a sovereign state on head of state immunity matters.
- Representation of a specialist engineering firm in determining and negotiating its contractual rights and obligations after contractual performance was disrupted by armed conflict.
- Representation of a major natural resource company in an investment dispute.
- Representation of an investor in Crimea in an investment dispute.
Pro Bono
- Representation of criminal defendants in Maryland courts.
- Representation of a nonprofit organization in a Federal FOIA lawsuit.
Memberships and Affiliations
- Professorial Lecturer in Law (International Arbitration), George Washington University Law School
- Member, American Society of International Law
Previous Experience
- National Serviceman, Singapore Armed Forces (2006-2008)
April 2, 2021, Covington Alert
On Thursday, April 1, 2021, the Financial Crimes Enforcement Network (“FinCEN”) released an advance notice of proposed rulemaking ("ANPR"), presenting the public with its first opportunity to comment on the beneficial ownership disclosure requirements in the Corporate Transparency Act ("CTA"), a key component of the Anti-Money Laundering Act of 2020 ("AMLA"). ...
February 8, 2021, Covington Alert
On February 1, 2021, the Myanmar military seized control of the government, detaining senior civilian leaders including State Counsellor Aung San Suu Kyi and President Win Myint. The UN Security Council, G7, and multiple governments condemned the coup and called for the release of civilian leaders. The United States determined that the military’s actions ...
January 27, 2021, Covington Alert
The Panel of Recognised International Market Experts in Finance (or “PRIME Finance”) announced last week a consultation on updates to its arbitration rules (the “PRIME Rules”), which were last updated in 2016 (the “2016 Rules”). The newly proposed rules (the “Proposed Rules”) will apply to disputes under previously concluded PRIME Finance arbitration agreements, ...
January 13, 2021, Covington Alert
On January 1, 2021, the United States Congress enacted the Anti-Money Laundering Act of 2020 (the “AMLA”), as part of the National Defense Authorization Act (the “Act”). The AMLA includes extensive and fundamental reforms to anti-money laundering (“AML”) laws in the United States, including the Bank Secrecy Act (“BSA”). We described the principal reforms — ...
December 15, 2020, Cov Financial Services
On December 10, the Financial Crimes Enforcement Network (FinCEN) issued new guidance interpreting section 314(b) of the USA PATRIOT Act and rescinding FinCEN’s previous guidance. Section 314(b) is intended to establish a safe harbor for financial institutions that voluntarily share (in accordance with the statute’s terms) information regarding possible ...
US to reform AML rules
December 14, 2020, Global Banking Regulation Review
Nikhil Gore is quoted in Global Banking Regulation Review regarding reform to the anti-money laundering framework as part of the National Defense Authorisation Act (NDAA), introducing a new beneficial ownership registration regime for shell companies. Mr. Gore says the beneficial ownership registry “helps make sure that banks, which are very much invested in ...
December 11, 2020, Covington Alert
On December 8, 2020, the House passed the National Defense Authorization Act (the “NDAA” or “Act”), which includes over 200 pages of significant reforms to the Bank Secrecy Act (“BSA”) and other anti-money laundering (“AML”) laws that have been working their way through Congress for several years. Despite some remaining objections from President Trump and ...
November 23, 2020, Global Policy Watch
On November 19, 2020, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the “Agencies”) issued a joint fact sheet clarifying how banks subject to the Bank Secrecy Act (“BSA”) should ...
November 22, 2020, Cov Financial Services
On November 19, 2020, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the “Agencies”) issued a joint fact sheet clarifying how banks subject to the Bank Secrecy Act (“BSA”) should ...
September 21, 2020, Covington Alert
On September 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (the “ANPR”) seeking public comment on significant potential amendments to anti-money laundering (“AML”) regulations under the Bank Secrecy Act (“BSA”). The ANPR proposes three principal changes to the current BSA/AML regime — in ...
August 19, 2020, Global Policy Watch
As we noted in a client alert late last week, the federal banking agencies released on August 13, 2020, a joint statement on enforcement of Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) requirements. At the time, the Federal Deposit Insurance Corporation made reference to a possible separate “Statement on Enforcement of the Bank Secrecy Act” from ...
August 18, 2020, Cov Financial Services
As we noted in a client alert late last week, the federal banking agencies released on August 13, 2020, a joint statement on enforcement of Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) requirements. At the time, the Federal Deposit Insurance Corporation made reference to a possible separate “Statement on Enforcement of the Bank Secrecy Act” from ...
August 14, 2020, Covington Alert
On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (the Agencies) issued joint guidance to clarify and update their policies with respect to the enforcement of the Bank Secrecy Act’s (BSA’s) anti-money laundering (AML) program requirement.[1] ...
The Panama Papers – Their Impact Today
August 13, 2020, American Bar Association
FinCEN Releases Guidance Regarding Due Diligence under the BSA for Hemp-Related Business Customers
July 6, 2020, Covington Alert
On June 29, 2020, the Financial Crimes Enforcement Network (“FinCEN”) released guidance regarding financial institutions’ Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) risk considerations with respect to hemp-related businesses.[1] The guidance is intended to enhance the access of lawful hemp-related businesses to financial services and ...
June 3, 2020, Covington Alert
On May 27, 2020, the Federal Reserve Bank of Boston ("FRBB") posted a number of documents that provide important additional details about its Main Street Lending Program ("MSLP"), including updated FAQs, new required agreements and forms, and new lender and borrower guides. The following summary highlights key FAQ changes and summarizes each of the new MSLP ...
May 4, 2020, Covington Alert
On May 4, 2020, the Federal Reserve Bank of New York (the “FRBNY”) released an updated series of Frequently Asked Questions (“FAQs”) regarding two of the Federal Reserve’s liquidity facilities established to provide financial assistance to businesses impacted by the COVID-19 pandemic: the Primary Market Corporate Credit Facility (“PMCCF”) and the Secondary ...
May 1, 2020, Covington Alert
Yesterday, April 30, 2020, the Board of Governors of the Federal Reserve System announced important changes to the Main Street Lending Program (the “Program”) that it had introduced on April 9, 2020. The changes reflect further information and clarification with respect to the terms and conditions of the Program and address, at least in part, feedback that the ...
April 23, 2020, Covington Alert
As the Paycheck Protection Program (“PPP”) is about to re-open following passage of a bill that will provide additional $310 billion in funds to the program (including funds reserved for loans by certain small and mid-sized lenders), the rules of the Small Business Administration (“SBA”) that prohibit or restrict loans to the small business ventures of bank ...
April 9, 2020, Covington Alert
Today, the Board of Governors of the Federal Reserve announced the creation of four new liquidity facilities and the expansion of three previously announced liquidity facilities to provide credit to borrowers impacted by the COVID-19 pandemic. Whereas the previously announced programs primarily targeted certain financial markets and their participants (such as ...
March 24, 2020, Covington Alert
On March 23, the Board of Governors of the Federal Reserve System (the “FRB”) announced the latest in a series of extraordinary actions intended to help mitigate the impacts of the COVID-19 pandemic on the U.S. economy. Unlike the measures announced last week – which mostly involved re-establishing emergency programs that were used during the 2008–09 financial ...
March 19, 2020, Covington Alert
Yesterday, on March 18, 2020, the Board of Governors of the Federal Reserve System (“Board”) announced the creation of a Money Market Mutual Fund Liquidity Facility (“MMLF”) to provide liquidity support to money market mutual funds (“MMMFs”) by facilitating their sale of certain assets in order to meet redemption requests. Under the MMLF, the Federal Reserve ...
March 18, 2020, Covington Alert
Yesterday, on March 17, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced the creation of a Primary Dealer Credit Facility (“PDCF”) to provide a liquidity backstop to primary dealers of the Federal Reserve Bank of New York (“FRBNY”), which include the nation’s largest broker-dealers. The PDCF will provide short-term loans to primary ...
March 17, 2020, Covington Alert
Today, on March 17, 2020, the Federal Reserve provided a backstop of commercial paper ("CP") in the form of a Commercial Paper Funding Facility (“CPFF”) that establishes a special purpose vehicle (“SPV”) to acquire eligible CP directly from eligible issuers. The CPFF will provide liquidity to CP issuers that may otherwise face issues rolling over their CP in ...
Federal Reserve Takes Extraordinary Actions Supporting Financial Markets to Mitigate COVID-19 Impact
March 16, 2020, Covington Alert
Yesterday, on Sunday, March 15, 2020, in response to the COVID-19 pandemic’s impact on U.S. and global economic activity, the Federal Reserve’s Federal Open Market Committee (“FOMC”) cut the target range of the federal funds rate to 0 to 1/4 percent until such time as the FOMC is “confident that the economy has weathered recent events and is on track to achieve ...
Covington Represents Ukraine in Securing Favorable Ruling Under U.N. Law of the Sea Convention
February 21, 2020
WASHINGTON—Covington secured a major ruling for Ukraine in an arbitration against the Russian Federation under the U.N. Convention on the Law of the Sea (UNCLOS). The ruling, issued today by a five-member arbitral tribunal, rejected the majority of Russia’s jurisdictional objections and permits Ukraine’s case to proceed to the merits. “The Tribunal’s ...
November 19, 2019, Covington Alert
In a recent Interpretive Letter, the Office of the Comptroller of the Currency (OCC) addressed a proposal from an OCC-regulated bank to automate its process for filing suspicious activity reports (SARs) under the Bank Secrecy Act (BSA).
Young Arbitrator Debate Series - This House believes human rights law has a role to play in investment arbitration
October 23, 2019
October 14, 2019, Cov Financial Services
On Friday, the leaders of the Securities and Exchange Commission (“SEC”), Commodity Futures Trading Commission (“CFTC”), and Financial Crimes Enforcement Network (“FinCEN”) (collectively, the “Agencies”) issued a “Joint Statement on Activities Involving Digital Assets” (the “Joint Statement”). The Joint Statement serves as a reminder that businesses engaged in ...
Covington Promotes from Ukraine Team
October 2, 2019, Global Arbitration Review
Nikhil Gore and Erin Thomas spoke with Global Arbitration Review about their recent promotion to partnership and contributions to the Covington’s Naftogaz team representing Ukrainian state-owned energy company Naftogaz in its $5 billion treaty claim against Russia over the seizure of its assets in Crimea.
October 2, 2019, The American Lawyer
Covington Promotes Its Most Diverse Partner Class Ever
October 1, 2019
WASHINGTON—Covington has promoted to its partnership 14 lawyers based in eight different offices, including nine women and six lawyers of ethnically diverse backgrounds. “Our new partners are exceptionally talented lawyers from a wide range of the firm’s offices and most important practices, and they are extremely well-positioned to carry the firm forward,” ...
August 15, 2019, Cov Financial Services
In the past few weeks, both Federal Deposit Insurance Corporation (“FDIC”) Chairman Jelena McWilliams and Comptroller of the Currency Joseph Otting have spoken publicly about ongoing efforts by their agencies, and by the Federal Reserve Board, to reform regulations implementing the Community Reinvestment Act (“CRA”). The federal bank regulatory agencies have ...
May 25, 2019, Cov Financial Services
The Office of the Comptroller of the Currency (OCC) released earlier this week its Semmiannual Risk Perspective for Spring 2019. The 30-page report, authored by the OCC’s National Risk Committee, reflects the agency’s view of current risks facing OCC-regulated banks. One of the functions of the National Risk Committee is to guide bank examiners on...… Continue ...
Covington Represents Ukraine in Securing Order for Release of Servicemen and Naval Vessels
May 25, 2019
WASHINGTON—Advised by Covington, Ukraine’s Ministry of Foreign Affairs secured a significant victory against the Russian Federation in a dispute arising under the U.N. Convention on the Law of the Sea. The International Tribunal for the Law of the Sea (“ITLOS”), a 21-judge international tribunal based in Hamburg, ordered Russia to release three Ukrainian naval ...
February 21, 2019, Cov Financial Services
On February 13, the European Commission published a list of 23 jurisdictions that it views as posing “significant threats to the financial system of the [European] Union” in the area of anti-money laundering and counter-terrorist financing (“AML/CFT”). On the same day, the U.S. Treasury Department issued a press statement in which it advised that it...… ...
December 21, 2018, Cov Financial Services
It took some time for banking lawyers and compliance officers to get used to the Consumer Financial Protection Bureau’s (CFPB’s) announcement, under former Acting Director Mick Mulvaney, that it would refer to itself as the Bureau of Consumer Financial Protection (BCFP). This blog — like many others in the industry — made sure to follow...… Continue Reading
December 18, 2018, Cov Financial Services
The Board of Directors of the Federal Deposit Insurance Corporation (FDIC) today approved its operating budget for 2019. The budget reflects a decrease in both expenditures (down 2.3%) and headcount (down approximately 3%). The FDIC’s budget memorandum explains that these changes reflect, among other things, consolidation in the industry and a decrease in the ...
September 18, 2018, Cov Financial Services
Late last week, the Commodities Futures Trading Commission (CFTC) and the Monetary Authority of Singapore (MAS) announced a cooperation agreement on FinTech innovation. The agreement is principally focused on information sharing on FinTech trends and developments and on each regulator’s FinTech sandboxes. The agreement could also, however, help FinTech ...
September 5, 2018, Covington Alert
This client alert summarizes recent regulatory developments relating to fintech and discusses the implications of these developments.
June 14, 2018, Covington Alert
This week has brought three significant developments in Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) regulation and legislation.
February 3, 2017, Covington Alert
Throughout his campaign, President Donald Trump promised to curtail financial regulations, particularly those promulgated under the Dodd-Frank Act. President Trump argued frequently that the regulations issued under the act have proven overly burdensome and, among other things, limited job growth. This afternoon, the President took his first formal step in ...
May 5, 2016, Covington Alert
Today, the Consumer Financial Protection Bureau published a proposed rule substantially curtailing the ability of financial services firms and consumers to enter into voluntary pre-dispute arbitration clauses. The proposed rule would prevent financial services providers from including arbitration clauses in consumer contracts unless those arbitration clauses ...
February 8, 2016, BNA's Banking Daily
December 30, 2015, BNA's International Trade Daily
November 17, 2015, Global Policy Watch
Note: This post is the second in a series of posts on the final text of the Trans-Pacific Partnership (TPP) by Covington’s International and Public Policy lawyers. The final TPP text, which was released on November 5, 2015, is available here. TPP is not expected to enter into force until at least 2016, with the timeline...… Continue Reading
October 15, 2015, Covington Alert
India’s Investment Treaties – Will the Government Reject a Core Standard of Investment Protection?
May 18, 2015, Global Policy Watch
Almost all of the more than 3,000 bilateral investment treaties (BITs) in existence offer foreign investors the protection of “fair and equitable treatment” under international law. India’s new draft model BIT does not. In place of the well-established standard of protection, which has been interpreted and applied in hundreds of prior investment arbitrations, ...
January 26, 2015, Global Policy Watch
One of the items at the top of President Obama’s agenda in India this week is the long-delayed U.S.-India bilateral investment treaty (BIT). Such a treaty was proposed by the President during his 2010 visit to India, but the proposal got little traction with the prior government. It is likely to do better with the...… Continue Reading
July 10, 2014, Global Policy Watch
On July 9, Indonesians went to the polls to vote for the nation’s second directly-elected President. Neither candidate has conceded, and official results will not be announced until July 22. However, independent polling and election monitoring organizations point to the loss of Prabowo Subianto, a Suharto-era general, to relative newcomer Joko Widodo, a ...
April 30, 2014, BankDirector.com
February 24, 2014, Covington E-Alert
2010, 34 Harvard Environmental Law Review 577
- Washington DC Super Lawyers, International "Rising Star" (2018)
COVID-19: Legal and Business Toolkit
We are helping clients around the world navigate this evolving, complex situation.