Photo of Elizabeth A. Khalil

Elizabeth A. Khalil Member

Areas of Practice


Bar Admissions

  • Illinois
  • District of Columbia
  • Massachusetts
  • Michigan
  • New York


University of Michigan Law School, J.D., 2002

Georgetown University, B.S., cum laude, 1999





Elizabeth Anne Khalil is a Member in Dykema’s Government Policy Practice Group. She focuses her practice on all aspects of regulatory compliance and risk management for the financial services industry, including consumer protection, privacy/data security, third-party relationships, Bank Secrecy Act/anti-money-laundering (BSA/AML), and the full “alphabet soup” of federal banking laws and regulations. She is a Certified Information Privacy Manager (CIPM) as certified by the International Association of Privacy Professionals (IAPP) and also holds two additional IAPP certifications: the CIPP/US (US privacy) and CIPP/E (European privacy) credentials.

Ms. Khalil advises clients on improving their overall compliance management systems and particular compliance programs, including privacy/data security programs, BSA/AML programs, and third-party/vendor management programs. She also regularly drafts and revises individual policies and procedures within a program. She also provides counsel on permissible bank and bank holding company activities and assistance with corporate applications, including regulatory due diligence in connection with mergers and acquisitions. Ms. Khalil also provides granular subject matter expertise on laws and regulations such as the following:

  • BSA/AML and Office of Foreign Assets Control (OFAC) regulations and policies
  • Privacy and data security laws and regulations, including the Gramm-Leach-Bliley Act (GLBA)/Regulation P, Fair Credit Reporting Act (FCRA), Children’s Online Privacy Protection Act (COPPA), the Telephone Consumer Protection Act (TCPA) and CAN-SPAM Act, the General Data Protection Regulation (GDPR), and state data protection and data breach notification laws
  • Unfair or deceptive acts or practices (UDAP) under the Federal Trade Commission Act and unfair, deceptive, or abusive acts or practices (UDAAP) under the Dodd-Frank Act
  • Electronic Fund Transfer Act (EFTA)/Regulation E
  • Truth in Savings Act (TISA)/Regulation DD
  • Expedited Funds Availability Act (EFAA)/Regulation CC
  • Truth in Lending Act (TILA)/Regulation Z
  • Real Estate Settlement Procedures Act (RESPA)/Regulation X
  • Fair lending and other antidiscrimination laws, including the Equal Credit Opportunity Act (ECOA)/Regulation B and Fair Housing Act (FHA)
  • Community Reinvestment Act (CRA)
  • Military Lending Act (MLA) and Servicemembers Civil Relief Act (SCRA)
  • Flood insurance laws and regulations
  • Electronic Signatures in Global and National Commerce Act (E-SIGN)
  • Bank Holding Company Act/Regulation Y
  • Federal Deposit Insurance Act (FDI Act)

Ms. Khalil was for many years a federal banking regulator at the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) in Washington, DC. At the OCC, she was an enforcement attorney and specialist in compliance and consumer protection issues. She was a member of numerous interagency teams, including those that wrote regulations implementing the FACT Act amendments to FCRA. At the FDIC, she served as Acting Special Assistant to both the Deputy Director and Director of the FDIC’s Division of Depositor and Consumer Protection, helping to oversee the agency’s nationwide compliance supervision program and community banking initiatives. She also advised senior FDIC officials on deposit insurance and emerging issues affecting consumers and the banking industry, including virtual currency and mobile financial services. Ms. Khalil also led the interagency team that created the first federal compliance guidance on use of social media by banks and credit unions. 

Ms. Khalil also served as a senior associate at an AmLaw 100 firm in Washington, DC, where she served in both the Financial Institutions and Privacy practice groups. There, she advised a wide variety of clients — including large, complex banks operating worldwide, community banks, and private equity investors — on matters including Dodd-Frank Act implementation strategies; enforcement actions; acquisition of banks, including bidding on failing banks marketed by the FDIC; novel uses of consumer data; and enterprise-wide privacy and data security programs.

Ms. Khalil is a frequent author and speaker on regulatory matters. She is a contributor to Lexis Practice Advisor and is a member of its advisory board.

Memberships & Involvement

International Association of Privacy Professionals (IAPP), Member

Illinois State Bar Association, Privacy and Information Security Law Section, Member, 2018-2019

Federal Communications Bar Association

American Bankruptcy Institute

Chicago Bar Association