Federal regulatory agencies are closely monitoring crypto-asset developments and banking organizations’ participation in the crypto-asset industry. This GT Alert covers the guidance issued by the FDIC, CFPB, and the Federal Reserve which especially highlights the risks associated with bank and non-bank partnerships.

Continue reading the full GT Alert.

Tags: banking, CFPB, cryptocurrency, FDIC, Federal Reserve Systems, Financial Regulatory Compliance, GT Insight
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Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice

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Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including private and public financings, dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. She serves as a trusted advisor to public and private company boards of directors on governance matters and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and public and private companies in emerging technology, life sciences and biotechnology, defense and security, blockchain and digital assets, telecommunications, information technology, energy (traditional and renewable), mining, media, entertainment and sports. Barbara also represents Olympic and professional athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 1997 with Sullivan & Cromwell, LLP, and headed the international capital markets practice of Kirkland & Ellis LLP from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters, strategic alternatives, and digital asset structures. She serves on the Government of Bermuda’s Global FinTech Advisory Board.

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Photo of William Mack William Mack

William B. Mack is a co-chair of the Financial Regulatory and Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority

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William B. Mack is a co-chair of the Financial Regulatory and Compliance Practice. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority (FINRA) rules.

William’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization (SRO) membership, supervision, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, use of foreign finders, anti-money laundering rules, alternative trading systems (ATS), exchanges, and market making issues. He also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Benjamin M. Saul Benjamin M. Saul

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped

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Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped clients navigate dozens of contentious supervisory, enforcement, and litigation matters involving the Consumer Financial Protection Bureau (CFPB), and has been a leader in the private bar on CFPB matters since the Bureau’s inception in 2011. He also routinely assists clients in matters involving the FTC, DOJ, HUD, OCC, FRB, FDIC, state financial services authorities, state attorneys general, and state civil rights commissions. Ben’s enforcement matters have concerned fair lending and servicing, unfair deceptive and/or abusive trade practices, other federal and state consumer finance laws, AML/BSA, troubled or failed banks, fiduciary duties, financial institution fraud, supervisory ratings, and other safety and soundness issues.  These matters often have involved parallel proceedings by multiple enforcement agencies and/or private parties.

Ben also advises lenders, servicers, alternative financial service providers, and money service businesses on product and service development, licensing, compliance program enhancement, and the applicability of federal and state consumer credit and other financial services laws. He frequently helps clients understand how financial services law maps onto new technologies and innovative products, having worked on matters involving big data, artificial intelligence, marketplace and online lending, blockchain, digital assets and cryptocurrencies, digital banking, and payment systems.  In addition, Ben provides financial services regulatory support for corporate and capital markets transactions.

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Photo of John B. Hutton III John B. Hutton III

John B. Hutton III is a restructuring advisor and a bankruptcy litigator who has spent his entire career with Greenberg Traurig since joining the firm in 1993. He has wide-ranging experience representing debtors, trustees, secured and unsecured creditors, asset purchasers, indenture trustees and…

John B. Hutton III is a restructuring advisor and a bankruptcy litigator who has spent his entire career with Greenberg Traurig since joining the firm in 1993. He has wide-ranging experience representing debtors, trustees, secured and unsecured creditors, asset purchasers, indenture trustees and bondholders across various industries, with a particular focus on municipal finance/ tax-exempt bonds, real estate, and hospitality. John litigates issues involving cash collateral, adequate protection, valuation, stay relief, feasibility and plan confirmation treatment. In his early years with the firm, John played a key role in the Southeast Banking Corporation bankruptcy case, one of the largest bank holding companies in Florida, which returned over 100 percent to creditors, along with post-petition interest. He has also had multiple Committee representations, including Mission Health, where the recovery for unsecured creditors was increased from a projected 10 percent to 90 percent. The U.S. Trustee called it the “most aggressive” Committee she had seen in her career. John has broad experience in handling indenture trustee and bondholder representations involving tax-exempt community development district bonds and the issues arising in such cases.

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