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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 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.

On July 14, 2025, U.S. banking regulators issued a joint statement clarifying risk management and legal expectations for banks handling crypto-asset safekeeping. While not introducing new rules, the guidance marks a shift to principles-based oversight, urging banks to independently assess and mitigate crypto-related risks in line with established safety and soundness standards.

Continue Reading Federal Banking Regulators Issue Guidance on Risk Management for Crypto-Asset Safekeeping Activities

On July 18, 2025, President Trump enacted the GENIUS Act, the first comprehensive crypto legislation in U.S. history. The law introduces rigorous rules for payment stablecoins, including mandatory federal or state approval, 1:1 reserve backing, and enhanced disclosure obligations. Digital asset service providers must fully comply by July 2028.

Continue Reading GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States

The Board of Governors of the Federal Reserve System (Board) has withdrawn supervisory guidance for Board-supervised banks concerning crypto-asset and dollar token activities and Board expectations for these activities. The Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) also withdrew joint supervisory statements on crypto-asset activities and exposures.

Continue Reading Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks

In late April, at the government’s request, an Indiana federal judge put a final end to the prosecution of an Indiana man for allegations that he engaged in unlicensed money transmission (and related tax offenses) in connection with his operation of a virtual currency exchange from 2009 to 2013.

Continue Reading Charges Dropped Against Early Cryptocurrency Exchange Operator

The California Department of Financial Protection and Innovation (DFPI) on April 4, 2025, issued its formal notice of rulemaking for digital financial business regulation, following receipt of two sets of 2024 comments on its draft proposed rules for California’s “Digital Finance Assets Law” (DFAL) (AB 39 and SB 401, 2023).
Continue Reading California DFPI Issues Formal Rulemaking for Digital Financial Asset Regulation

On Jan. 25, 2024, the Hawaii Department of Commerce and Consumer Affairs Division of Financial Institutions (DFI) and the Hawaii Technology Development Corporation (collectively, the “Agencies”) jointly issued a press

Continue Reading Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities
  1. Continued Robust Litigation and Enforcement Actions by Federal and State Regulators and Enforcement Authorities – We will likely see a similar level of anti-fraud prosecutions by the Department of Justice
Continue Reading 5 Trends to Watch: 2024 Blockchain

On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and

Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing

On Sept. 18, 2023, the New York State Department of Financial Services (NYDFS) issued a press release announcing updates to its ongoing oversight of the digital asset space, including (1)

Continue Reading NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist