How Hard Can It Be?

Hugo F. Sueiro’s philosophy has given him a wide range of expertise, including the complexities of the Volcker Rule

Whenever Hugo F. Sueiro gets involved in substantial undertakings, he asks himself one question: how hard can it be? It’s something he’s asked himself throughout his career, including as in-house counsel at BNP Paribas (BNPP).

“I like variety in my professional life, so when someone needs help on a project, I raise my hand,” explains Sueiro, who has been at BNPP for more than ten years. “I have been fortunate to have held positions that expose me to a lot of different practice areas while maintaining the stability of working for an employer for the long term.”

Sueiro, who grew up in Miami, Florida, comes by his passion, commitment, and hands-on approach naturally. His father, a Cuban immigrant to the US, was a veteran of the failed Bay of Pigs invasion of 1961. After being released from prison in Cuba, he volunteered for the US Army and served in Vietnam. Sueiro was also inspired by his mother who, along with her younger sister, immigrated from Cuba at the age of sixteen without their parents as part of Catholic refugee-resettlement program known as Pedro Pan. Growing up, Sueiro strongly identified with the experience of his father and his grandparents who had been poor in Cuba.

His family’s experiences helped fuel his lifelong interest in service work. While in high school and college, he spent three summers in the Dominican Republic working on small-scale development projects. Prior to law school, he co-founded One Nation Inc., a nonprofit organization that assisted over ten thousand people with applying for citizenship. To this day, he still does pro bono work with immigrants.

“I have been fortunate to have held positions that expose me to a lot of different practice areas while maintaining the stability of working for an employer for the long term.”

—Hugo F. Sueiro

After graduating from the University of Michigan Law School, Sueiro spent six years at Cleary, Gottlieb, Steen, and Hamilton in New York before joining BNPP in 2006. He was originally brought in to support the bank’s US capital markets and mergers and acquisitions areas. Since then, with a number of detours on the way, he has become BNPP’s legal expert on the Volcker Rule.

The Volcker Rule, passed in 2010 as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, restricts the ability of banks to engage in proprietary transactions and invest in or sponsor hedge funds and private equity funds.

According to Sueiro, it’s a complicated regulation, not only because of the intricacies of the financial industry, but also because of how key terms are defined. Its technical wording can lead to its application to investments it was not intended to regulate and omitting some higher-risk investments that should be covered.

A fair amount of Sueiro’s time is spent educating and advising various bank divisions about the rule. His goal is to help them understand the rule’s nuanced subtleties, when it applies, and how to recognize potential red flags that need to be brought to his attention.

“A common misconception people have is assuming that because an activity is ‘business as usual’ that it is permissible from a regulatory standpoint,” he says. “Sometimes even small changes to an otherwise ‘plain vanilla’ structure can create issues for the bank. My job is to help interpret what the law says, decide if it applies, and clarify what procedures are required.”

Sueiro’s “how hard can it be” spirit led to his role as lead counsel for BNPP’s Foreign Exchange Prime Brokerage (FXPB) business, a new type of business that he knew very little about. He originally volunteered to work on the acquisition of the FXPB business from another financial institution in 2009. After the acquisition had closed, he stayed on to assist with the integration of the FXPB business into the bank. He created a suite of legal documents and helped design comprehensive policies and procedures.

“I’m proud of my work on FXPB because it was like being an entrepreneur and creating something from scratch,” Sueiro says. “Without existing scripts to work from, we assessed the risks of the business, developed a series of procedures and documents that we felt were better than anything else in the market, and created tangible value for the bank.”

The Volcker Rule and Sueiro’s involvement with it are always evolving. Since the rule was adopted, the regulators have periodically issued interpretive guidance that, in certain cases, have had important effects on the financial industry.

“The pendulum has slowly begun to swing in the direction of unwinding some of the unintended effects of the Volcker Rule, making our compliance and educational efforts somewhat easier,” he points out.

Perhaps because of this, Sueiro has started looking into taking on a new project. How hard could that be?


“Hugo is a skilled, versatile, and dedicated lawyer and a good friend of the firm. Cleary Gottlieb values our long-term relationship with him and looks forward to continuing our work together.” —Derek Bush, partner at Cleary Gottlieb Steen & Hamilton LLP