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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 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




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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