Davis Polk AML/CFT head Dan Stipano was quoted in Fintech Takes discussing Riggs Bank, a major Washington, D.C. commercial bank that was famous for having presidential ties before being acquired in 2005 following money laundering allegations. 

The article noted that the bank started an embassy business in the early 20th century. 

“Embassy banking is interesting, because it can be very high risk for [money laundering] or it can also be very low risk,” Dan said. “There’s not normally a lot of money going through the accounts and the funds are typically used for mundane expenses like paying the embassy’s staff and utility bills. Generally, they’re very boring — except for the ones that aren’t.”

This was complicated when, after the September 11th attacks, “literally overnight [Bank Secrecy Act compliance went from a] somewhat arcane compliance area to a matter of national security,” he explained.

In 2005, the OCC levied a $25 million fine for failing to file suspicious activity reports. 

“That was the largest civil money penalty that the OCC had assessed up to that point,” Dan noted, adding that “while this amount seems small by today’s standards, it was groundbreaking at the time.”

Dan said, “Riggs Bank got caught in shifting winds.” Regulators had raised their expectations for banks’ anti-money laundering controls significantly, but “the way they operated was the way they had always operated.”

“The Fall of the House of Riggs,” Fintech Takes (June 16, 2026)

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