Daniel P. Stipano
Extensive bank regulatory and enforcement experience that includes more than 30 years at the OCC. Advises on regulatory enforcement actions and BSA/AML matters.
Dan represents clients in state, federal and foreign regulatory enforcement actions, and provides assistance in establishing, maintaining and monitoring Bank Secrecy Act and 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 oversaw major OCC enforcement actions. He played a key role in significant BSA/AML rulemakings and policy issuances. 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.
Dan's representations before joining Davis Polk include the following:
- Representing a federal savings bank regarding OCC 15-day letters based on compliance deficiencies
- Representing a former state member bank employee in a Federal Reserve Board enforcement proceeding that resulted in a consent cease and desist order, and a national bank employee and a former national bank employee regarding OCC 15-day letters that resulted in letters of reprimand
- Drafting BSA/AML policies and procedures for a federal branch of a foreign bank, a broker-dealer and a blockchain-based consumer lender
- Representing a state nonmember bank in an OFAC investigation resulting in issuance of a cautionary letter
- Advising a state nonmember bank on its response to a 15-day letter in a Federal Deposit Insurance Corporation (FDIC) civil money penalty (CMP) proceeding that resulted in no CMP assessment
- Advising a state member bank concerning its policies, procedures, and controls with respect to a customer’s business activities in Cuba
Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)
- Partner, Davis Polk, 2021-present
- 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