Daniel P. Stipano
Extensive bank regulatory and enforcement experience that includes more than 30 years at the OCC. Advises on AML/CFT matters and regulatory actions.
Dan advises banks, broker-dealers, fintech, money services and cryptocurrency businesses and payment providers on the design, implementation and remediation of anti-money laundering / countering the financing of terrorism (AML/CFT) compliance programs. He also conducts internal investigations and has represented banks and individuals in enforcement actions and investigations brought by every federal banking agency and FinCEN.
Dan served for over 30 years at the Office of the Comptroller of the Currency; as its Deputy Chief Counsel, he played a central role in significant Bank Secrecy Act (BSA) rulemakings and policy initiatives and oversaw major enforcement actions. He has testified six times before Congress on enforcement and AML/CFT matters.
Leveraging his unique combination of policymaking, supervisory and enforcement experience, Dan provides practical guidance to clients as they develop new products, expand their regulatory footprints, strengthen their compliance frameworks and respond to regulatory issues.
Experience
Dan’s recent representations include the following:
- Representing a national bank in an OCC cease and desist action
- Advising a national bank with respect to development of a compliance risk management framework for digital asset activities
- Conducting a review of a major stablecoin issuer’s financial crimes policies
- Advising multiple applicants seeking to charter a de novo national trust bank
- Conducting a review of a large asset management firm’s financial crimes poiicies
- Advising a state-chartered bank with respect to its Banking as a Service platform
- Serving as counsel to the Board of Directors of a national bank
- Conducting a review of a broker-dealer’s onboarding policies for foreign clients
- Representing a national bank with respect to an OCC examination into potential BSA violations that resulted in no enforcement actions taken
- Co—leading an investigation into potential BSA violations at a national bank
- Advising the branch of a foreign bank with respect to examination issues
Insights
News
Recognition
Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)
IFLR1000 – Financial Services Regulatory, United States, Highly Regarded
Education
- summa cum laude
Prior experience
- Partner, Buckley, 2017-2020
- Office of the Comptroller of the Currency, 1985-2016
- Acting Chief Counsel, 2004-2005 and 2012
- 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