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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.

On July 18, 2025, President Trump enacted the GENIUS Act, the first comprehensive crypto legislation in U.S. history. The law introduces rigorous rules for payment stablecoins, including mandatory federal or state approval, 1:1 reserve backing, and enhanced disclosure obligations. Digital asset service providers must fully comply by July 2028.

Continue Reading GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States

On June 16, 2025, the Senate Finance Committee released its own version of the tax provisions of H.R. 1, entitled the “One Big Beautiful Bill Act,” which the U.S. House of Representatives passed on May 22, 2025. The full U.S. Senate is expected to debate the Senate Proposal in the days ahead, where additional changes may be made.
Continue Reading One Big Beautiful Bill Act – Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad

The Board of Governors of the Federal Reserve System (Board) has withdrawn supervisory guidance for Board-supervised banks concerning crypto-asset and dollar token activities and Board expectations for these activities. The Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) also withdrew joint supervisory statements on crypto-asset activities and exposures.

Continue Reading Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks

In late April, at the government’s request, an Indiana federal judge put a final end to the prosecution of an Indiana man for allegations that he engaged in unlicensed money transmission (and related tax offenses) in connection with his operation of a virtual currency exchange from 2009 to 2013.

Continue Reading Charges Dropped Against Early Cryptocurrency Exchange Operator

The California Department of Financial Protection and Innovation (DFPI) on April 4, 2025, issued its formal notice of rulemaking for digital financial business regulation, following receipt of two sets of 2024 comments on its draft proposed rules for California’s “Digital Finance Assets Law” (DFAL) (AB 39 and SB 401, 2023).
Continue Reading California DFPI Issues Formal Rulemaking for Digital Financial Asset Regulation

FinCEN recently issued an alert to warn U.S. financial institutions, particularly depository institutions and money services businesses (MBSs), of the risks and red flags associated with bulk cash smuggling by Mexico-based drug cartels and other transnational criminal organizations.

Continue Reading FinCEN Warns US Financial Institutions of Bulk Cash Smuggling Risks from Mexico-Based Cartels

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule (Final Rule) extending the recordkeeping requirement for compliance with U.S. economic sanctions regulations from five to 10 years.
Continue Reading US Treasury Extends Recordkeeping Requirement for Economic Sanctions Compliance to 10 Years

On March 21, 2025, FinCEN issued an interim final rule narrowing the scope of the CTA’s BOI Reporting Rule (Reporting Rule) to foreign reporting companies and foreign beneficial owners.

Continue Reading FinCEN Issues Interim Final Rule Exempting Domestic Companies and US Beneficial Owners From Reporting Requirements

The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other things, report and maintain records of cash transactions exceeding $200 (up to $10,000), and to verify the identity of persons presenting such transactions
Continue Reading Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200

Since taking office, President Trump reduced the Consumer Financial Protection Bureau’s influence by appointing Russell Vought as acting director, who paused rulemaking, enforcement, and other CFPB activities. This shift impacts bank-fintech partnerships, requiring industry adjustments.
Continue Reading The Current And Future State Of Bank-Fintech Partnerships