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Daniel P. Stipano


Daniel P. Stipano

Financial Institutions
Washington DC

Extensive bank regulatory and enforcement experience that includes more than 30 years at the OCC. Advises on regulatory actions and BSA/AML matters.

Dan represents clients in regulatory matters, including state and federal regulatory enforcement actions, and provides assistance in establishing, maintaining and monitoring Bank Secrecy Act / anti-money laundering (BSA/AML) compliance programs.

His regulatory and enforcement experience includes more than 30 years at the Office of the Comptroller of the Currency (OCC). As Deputy Chief Counsel from 2000-2016, Dan played a key role in significant BSA/AML rulemakings and policy issuances and oversaw major OCC enforcement actions. While at the OCC, Dan supervised more than a dozen successful appeals. He was instrumental in bringing the first fair lending action taken by a federal banking agency against a bank and the first Unfair or Deceptive Acts or Practices action taken against a bank.

Dan has testified six times before Congress on enforcement and BSA/AML matters. He is a member of the advisory boards of ACAMS and the ABA/ABA Financial Crimes Enforcement Conference.

Experience highlights

Dan’s recent representations include the following:

  • Representing a federal branch of a foreign bank with respect to a consent cease and desist order based on BSA violations.
  • Representing a national bank with respect to an OCC examination into potential BSA violations that resulted in no enforcement actions taken.
  • Representing state- and federally chartered banks with respect to the assessment of OCC and FinCEN civil money penalties based on BSA violations.
  • Representing a federally chartered bank with respect to a consent order based on deficiencies in its mortgage servicing practices.
  • Conducting an AML/sanctions policy review for a major crypto firm.
  • Advising banks, broker-dealers, money services businesses, fintech companies and crypto firms with respect to BSA/AML issues.




Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)

IFLR1000 – Financial Services Regulatory, United States

J.D., William & Mary Law School
B.A., Union College
Professional history
  • Davis Polk since 2021
  • Partner, Buckley, 2017-2020
  • Office of the Comptroller of the Currency, 1985-2016
    • Deputy Chief Counsel, 2000-2016
    • Director, Enforcement & Compliance Division, 1995-2000
    • Assistant Director, Enforcement & Compliance Division, 1989-1995
    • Staff Attorney, Enforcement & Compliance Division, 1985-1989
Qualifications and admissions
  • Commonwealth of Virginia
  • District of Columbia
  • U.S. Supreme Court
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