Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com discussing the OCC’s proposed guidance on how banks manage partnerships with fintechs and third-party vendors.

The article noted that the proposal comes during a period of broader regulatory focus on material financial risk and away from other areas, including anti-money laundering compliance.

“What is material for a bank that has trillions of dollars in assets? The answer is that basically nothing is,” Dan said, explaining that no single fintech or other third-party relationship reaches the threshold of posting a risk. “But banks can have small, manageable problems that do not come close to presenting material financial risk that can metastasize into larger, unmanageable ones,” he added.

Discussing how loosening third-party risk management standards for community banks could leave some lenders vulnerable to compliance failures, Dan noted, “Bank failures are costly not just in the financial sense. If a community bank fails, you could have a whole swath of people that now don’t have access to banking services.”

“Bank Third-Party Guidance Misses Financial Crime Risk: Ex-Regulators,” MoneyLaundering.com (September 17, 2026) (subscription required)

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