Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com discussing the impact of Supreme Court case Trump v. Slaughter, which gave the White House authority to terminate Senate-confirmed leaders of independent agencies at will, on the banking agencies.

“The ruling in Slaughter appears to be categorical because most independent regulatory organizations exercise executive functions and are therefore subject to the president’s authority,” Dan said. “But the [Trump v.] Cook case seems to walk it back and say, ‘Well, the Fed is special.’”

“It’s hard to reconcile the two decisions,” he added, referring to the Supreme Court decision barring the White House from removing a Federal Reserve governor without cause.

He also noted, “At the same time, the FDIC and NCUA both insure deposits for financial services companies, a ‘quasi private’ function central enough to the safety and stability of the banking system to possibly merit a carveout from the type of executive intervention validated by last month’s ruling.”

“[The two cases] appear to treat the Fed’s monetary policy functions differently, so maybe the door is open a crack here too,” Dan said. “Slaughter likely applies to the FDIC and NCUA in their supervisory capacities, but it’s not unquestionable.”

“Supreme Court Ruling Could Impact Federal Banking Agencies,” MoneyLaundering.com (July 6, 2026) (subscription required)

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