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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.

On Aug. 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information under the Corporate Transparency Act.
Continue Reading FinCEN Final Rule Permanently Ends Beneficial Ownership Reporting Requirements for US Companies and US Persons

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.
Continue Reading SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework

Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons).
Continue Reading Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements

  • Increasing Focus on AI — AI developments and uses and the evolving legal and regulatory landscape may bring about new litigation and enforcement risks stemming from claims of algorithmic bias, discrimination, errors made by autonomous AI agents, fraud perpetrated using AI, misuse relating to privacy and governance, monitoring and reporting, and other areas. Evolving theories
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In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”…
Continue Reading Federal and State Efforts Intensify Focus on ‘Debanking’

The U.S. Court of Appeals for the Eleventh Circuit in National Small Business United vs. U.S. Department of the Treasury reversed the decision of the U.S. District Court for the Northern District of Alabama decision, which found that the Corporate Transparency Act (CTA) is constitutional.

Click here to read the full GT Alert.

On Sept. 30, 2025, the OFR requested approval from the Florida Financial Services Commission to publish a Notice of Proposed Rule to amend Rules 69U-100.323 and 69U-100.3231 and for final adoption of the proposed amendments, subject to any request for a rule hearing.1 Rules 69U-100.323 and 69U-100.3231 implement the annual attestation requirement and complaint…

On Sep. 8, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it issued a new Geographic Targeting Order (September GTO) that renewed and modified FinCEN’s GTO announced on March 11, 2025 (March GTO).
Continue Reading Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing that it will extend the effective date of the final rule establishing anti-money laundering/countering the financing of terrorism program and suspicious activity report filing requirements for certain investment advisers and exempt reporting advisers (IA AML Rule), from Jan. 1, 2026, to Jan. 1, 2028.…

Continue Reading FinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its Scope