On Feb. 23, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a joint statement (Joint Statement) that highlights liquidity risks crypto-asset-related (CAR) funding sources pose to banking organizations and provides some effective practices to manage such risks.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. 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.

Photo of Steven T. Cummings Steven T. Cummings

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial…

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial Services, Steven supervised the virtual currency team in evaluating virtual currency applications for regulatory compliance with anti-money laundering, cybersecurity, and consumer protection requirements.