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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.

Experience highlights

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
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Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)
J.D., William & Mary Law School
B.A., Union College
Professional history
  • 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
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