Daniel P. Stipano
  1. Partner

Mr. Stipano is a partner in Davis Polk's Financial Institutions & Regulation Group, based in the Washington DC office. His practice includes representing clients in state, federal and foreign banking enforcement actions, and providing assistance in establishing, maintaining and monitoring Bank Secrecy Act and anti-money laundering compliance programs.

Mr. Stipano’s extensive bank 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 to 2016, he oversaw the OCC’s major enforcement actions up until the time of his departure. He also played a key role in significant BSA/AML rulemakings and policy issuances following the enactment of the USA PATRIOT Act. From 1995 to 2000, Mr. Stipano served as Director of the OCC’s Enforcement & Compliance Division.

While at the OCC, he supervised more than a dozen successful appeals, and was instrumental in bringing both the first fair lending action taken by a federal banking agency against a bank and the first Unfair or Deceptive Acts or Practices (UDAP) action taken against a bank.

Work Highlights

Mr. Stipano’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

Recognition

  • Chambers USA – Financial Services Regulation: Banking (Enforcement & Investigations)

Of Note

  • Advisory Board Member, Association of Certified Anti-Money Laundering Specialists (ACAMS)
  • Advisory Board Member, American Bankers Association/American Bar Association (ABA/ABA) Financial Crimes Enforcement Conference
  • Chair, Enforcement Subcommittee, ABA Banking Law Committee
  • Co-Chair, Cambridge Forum on Sanctions and Anti-Money Laundering
  • Executive Council Member, Federal Bar Association
  • Testified six times before Congress on enforcement and BSA/AML matters, and prepared OCC witnesses for testimony is this area
  • Frequent speaker at conferences and industry events

Professional History

  • Partner, Davis Polk, 2021-present
  • Partner, Buckley, 2017-2020
  • Office of the Comptroller of the Currency
    • 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

Bar Admissions

  • District of Columbia
  • Commonwealth of Virginia
  • U.S. Supreme Court

Education

  • B.A., Union College, 1980
  • J.D., William & Mary Law School, 1983