The OCC’s final debanking report examines reputation-risk practices and highlights continued fair-access scrutiny for national banks.
News & Commentary on Financial Regulatory and Compliance Matters
Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.
Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.
The OCC’s final debanking report examines reputation-risk practices and highlights continued fair-access scrutiny for national banks.…
The Federal Trade Commission has reached a proposed $12 million settlement with Humboldt Merchant Services based on allegations that it processed payments for merchants that were shell companies or engaged…
Continue Reading FTC Targets Payment Processor in Proposed $12 Million Sham-Merchant Settlement
On Aug. 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information under the Corporate Transparency Act.
Continue Reading FinCEN Final Rule Permanently Ends Beneficial Ownership Reporting Requirements for US Companies and US Persons
FinCEN published a proposed rule to reform anti-money laundering and countering the financing of terrorism program requirements for financial institutions under the Bank Secrecy Act.…
Continue Reading FinCEN Proposes Reforms to AML/CFT Program Requirements
On March 17, 2026, the U.S. Securities and Exchange Commission issued an interpretive release addressing the application of the federal securities laws to crypto assets and related transactions.
Continue Reading SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework
Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons).
Continue Reading Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements
In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”…
Continue Reading Federal and State Efforts Intensify Focus on ‘Debanking’
The U.S. Court of Appeals for the Eleventh Circuit in National Small Business United vs. U.S. Department of the Treasury reversed the decision of the U.S. District Court for the…
Continue Reading CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged
On Sept. 30, 2025, the OFR requested approval from the Florida Financial Services Commission to publish a Notice of Proposed Rule to amend Rules 69U-100.323 and 69U-100.3231 and for final…
Continue Reading Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules