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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 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.

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On March 17, 2026, the U.S. Securities and Exchange Commission issued an interpretive release addressing the application of the federal securities laws to crypto assets and related transactions. The Commodity Futures Trading Commission joined the interpretation and indicated it will administer the Commodity Exchange Act consistent with the SEC’s approach, reflecting a coordinated regulatory position across the two agencies.
Continue Reading SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework

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

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