On Jan. 25, 2024, the Hawaii Department of Commerce and Consumer Affairs Division of Financial Institutions (DFI) and the Hawaii Technology Development Corporation (collectively, the “Agencies”) jointly issued a press release summarizing their findings on the proper regulatory framework for companies specializing in digital currency activity (Crypto Companies)—concluding that the DFI will not apply the state’s Money Transmitters Act to cryptocurrency activities. As such, Crypto Companies will no longer require a Hawaii-issued money transmitter license to conduct business within the state. Crypto Companies will be able to operate in Hawaii as unregulated businesses.

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Photo of Hilary R. Sledge-Sarnor Hilary R. Sledge-Sarnor

Hilary R. Sledge-Sarnor represents businesses and financial institutions in a range of legal matters. Hilary has over 15 years of experience representing financial institutions, corporate borrowers, funds and fund sponsors in a broad range of syndicated cross-border and domestic financings. Hilary is experienced…

Hilary R. Sledge-Sarnor represents businesses and financial institutions in a range of legal matters. Hilary has over 15 years of experience representing financial institutions, corporate borrowers, funds and fund sponsors in a broad range of syndicated cross-border and domestic financings. Hilary is experienced in a wide range of industries, including technology, fund finance retail and entertainment. She regularly provides counsel on secured transactions and UCC Article 9.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. 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.

Photo of Lisa M. Lanham ‡ Lisa M. Lanham ‡

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders and servicers, marketplace lenders, and entities offering retail installment contracts for consumer goods. Moreover, she advises investors engaged in secondary market activities. Lisa also extends her support to emerging fintech firms, helping them to comply with necessary state licensing requirements and develop products in these realms while keeping regulatory demands in check.

A large part of Lisa’s role involves working closely with regulators such as the New York State Department of Financial Services to facilitate her clients’ pursuit of necessary business licenses and approvals. This not only includes completing audits and examinations but also covering intricate disclosure issues and reporting changes of ownership, executive management, and qualifying individuals. In addition to these tasks, Lisa was involved in the development of the Nationwide Multistate Licensing System & Registry (NMLS) 2.0 system. She handles virtually all aspects of the NMLS, including submissions and amendments of company application forms and electronic surety bonds.

Her contributions extend to representation and regulatory counsel in areas such as structured finance, securitization, secondary market transactions, licensing matters in mergers and acquisitions transactions, regulatory agency coordination for large-scale multistate transactions, and various financial service operations. In addressing state licensing matters, Lisa has contributed to notable projects such as assisting international crypto exchanges enter into the U.S. market by setting up compliant subsidiaries.

Lisa’s work also includes the reporting of material licensing changes, providing technical reviews, analyzing proposed business models in the context of regulatory compliance issues, assisting with the development of policies and procedures for regulatory compliance concerns, negotiating findings before examination report finalization, and managing international licensing issues amidst dynamic regulatory environment.

 Admitted in New York and Pennsylvania. Not admitted in Florida.

Photo of Steven T. Cummings Steven T. Cummings

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial…

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial Services, Steven supervised the virtual currency team in evaluating virtual currency applications for regulatory compliance with anti-money laundering, cybersecurity, and consumer protection requirements.

Photo of Janiell "Alexa" Gonzalez Janiell "Alexa" Gonzalez

Janiell A. Gonzalez focuses her practice on digital payments, money service businesses, money transmitter licensing, lender licensing, escrow licensing, and providing federal and state regulatory compliance guidance to cryptocurrency businesses, digital payment companies, fintechs, consumer and commercial lending companies, and banks. Janiell’s compliance…

Janiell A. Gonzalez focuses her practice on digital payments, money service businesses, money transmitter licensing, lender licensing, escrow licensing, and providing federal and state regulatory compliance guidance to cryptocurrency businesses, digital payment companies, fintechs, consumer and commercial lending companies, and banks. Janiell’s compliance related focus includes advice on matters concerning compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, the Corporate Transparency Act and implementing regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs.

She also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial and payments products and services. Janiell has a wide-ranging background in regulated entity compliance matters having served as an in-house corporate paralegal for large corporations in the health care and aviation industries. She now leverages this experience to provide strategic, practical and actionable advice to clients.