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Marina Olman-Pal

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.

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

  • Increasing Focus on AI — AI developments and uses and the evolving legal and regulatory landscape may bring about new litigation and enforcement risks stemming from claims of algorithmic bias,
Continue Reading Outlook 2026: Financial Services Litigation

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing that it will extend the effective date of the final rule establishing anti-money laundering/countering the financing of terrorism program and suspicious activity report filing requirements for certain investment advisers and exempt reporting advisers (IA AML Rule), from Jan. 1, 2026, to Jan. 1, 2028.

Continue Reading FinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its Scope

On July 14, 2025, the Federal Reserve, the OCC, and the FDIC issued a joint statement addressing risk management and legal expectations applicable to banking organizations engaging in crypto-asset safekeeping. The Statement follows the Agencies’ coordinated rescission earlier this year of interpretive guidance requiring advance supervisory non-objection for crypto activities.[1] While the Statement does not impose new regulatory requirements, it provides important guidance regarding how the Agencies expect banking organizations to manage the legal, operational, technological, and compliance risks associated with crypto-asset safekeeping.

Continue Reading Federal Banking Regulators Issue Guidance on Risk Management for Crypto-Asset Safekeeping Activities