Daniel P. Stipano
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.
Insights
News
Credentials
Recognition
Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)
IFLR1000 – Financial Services Regulatory, United States
Education
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