Frequently Asked Questions

Engage at the earliest credible signal of a strategic, regulatory, or technology shift — a planned digital transformation, an MRA or matter requiring attention from the OCC, FDIC, or NYDFS, a fintech partnership, a blockchain or stablecoin initiative, or a security or fraud incident.

Early engagement lets us scope the regulatory perimeter, design the governance and risk framework, and avoid the costly rework that follows when a product launches outside the rails of OCC Bulletin 2013-29 third-party risk management or FFIEC IT examination guidance. Late engagement narrows your strategic options and increases the probability of supervisory criticism, consent orders, or enforcement actions.

We are practitioners at the intersection of law, technology, and financial services regulation — not a Big Four advisory shop and not a pure law firm.

Our team includes attorneys, former regulators, court-appointed special masters, blockchain forensics specialists, and security technologists who have advised banks, fintechs, exchanges, and boards through every phase from charter applications and BSA/AML build-outs to enforcement defense and post-incident remediation. Engagements are led by senior personnel from intake through delivery — and, where required, through expert testimony.

We build a roadmap around three vectors: business strategy, regulatory perimeter, and technology architecture — sequenced so each milestone is defensible to the board, the regulator, and the customer.

The roadmap addresses target operating model, core modernization, channel strategy, data and analytics, customer experience, and the regulatory build (BSA/AML, CFPB UDAAP, fair lending, Reg E, FFIEC cyber, NYDFS Part 500) needed to support each release. See our digital banking strategy consulting services.

We treat every BaaS or fintech partnership as a third-party risk and supervisory exposure for the bank, not just a commercial deal.

Our work covers due diligence under OCC Bulletin 2013-29 and the 2023 Interagency Guidance on Third-Party Relationships, contract risk allocation, BSA/AML and OFAC program ownership, complaint and dispute handling under Reg E, CFPB UDAAP review of marketing and pricing, and ongoing oversight, audit rights, and exit planning. Recent enforcement actions against sponsor banks make a defensible governance program non-negotiable.

An effective program covers the FFIEC BSA/AML Examination Manual pillars — internal controls, independent testing, designated BSA officer, training, customer due diligence, and beneficial ownership — calibrated to the institution's products, customers, geographies, and channels.

For digital institutions we layer in transaction monitoring tuned to real-time payments (RTP, FedNow, Zelle, ACH same-day), CIP/CDD for fully digital onboarding, OFAC sanctions screening, SAR and CTR processes, and NYDFS Part 504 transaction monitoring and filtering certification where applicable. See our digital banking regulatory compliance capabilities.

We map every consumer-facing flow — disclosures, fees, dispute handling, model-driven decisions, marketing — against UDAAP, Reg E, ECOA/Reg B, TILA/Reg Z, and the CFPB's evolving guidance on junk fees, fraud-induced transfers, and AI-driven decisioning.

Where machine learning is used in underwriting or fraud, we build adverse action notice logic, model risk management under SR 11-7, and disparate-impact testing into the SDLC, not bolted on after launch. CFPB consent orders against neobanks and BaaS sponsors illustrate the cost of getting this wrong.

CSOs and CROs need an outside team that can stand up frameworks, defend them to examiners, and run them under fire during an incident or enforcement action.

We deliver enterprise risk and information security programs aligned with the FFIEC Cybersecurity Assessment Tool, NIST CSF 2.0, NYDFS Part 500, ISO 27001, and the SEC cyber disclosure rules — plus 24/7 incident response, board reporting, and tabletop exercises. See our CSO and CRO advisory service.

We build the legal and operational rails — money transmission, BSA/AML, sanctions, custody, market structure, and consumer protection — that allow blockchain and digital asset products to launch and scale.

Engagements cover FinCEN MSB registration, the FATF Travel Rule, NYDFS BitLicense and Wyoming SPDI structures, SEC vs CFTC jurisdictional analysis for tokens, stablecoin reserve and disclosure frameworks, and on-chain forensics for fraud, sanctions, and recovery matters. Learn more about our blockchain services.

Real-time payments and open banking compress decision windows from days to seconds, which means controls must move from periodic to continuous.

We help institutions build fraud, sanctions, and authorization frameworks for FedNow and RTP, design CFPB Section 1033 open banking data-sharing controls, and assess CBDC and tokenized deposit pilots against monetary policy, privacy, and operational resilience requirements. Each program is tested against board-level risk appetite before deployment.

Retain an expert when the dispute turns on industry standard of care, regulatory interpretation, or technical fact-finding that the trier of fact cannot evaluate without help.

Typical engagements include BSA/AML and OFAC adequacy, fraud and Reg E error-resolution disputes, cyber-incident liability, blockchain transaction tracing, model risk and AI underwriting, breach of fiduciary duty against directors, and FINRA, SEC, and CFTC enforcement matters. See our digital banking expert witness services.

We train at three levels — board, executive committee, and operational staff — because each audience needs different content to discharge its duties.

Programs cover BSA/AML and OFAC, cybersecurity and NYDFS Part 500, blockchain and digital assets, CFPB UDAAP and fair lending, third-party and BaaS risk, and incident-response tabletops. Sessions are delivered in person, virtually, or hybrid, and CLE credit can be arranged where relevant. See our digital banking training services.

We move in within hours, run the technical and legal investigation under privilege, and then build the remediation that satisfies the board, the regulator, and the plaintiffs' bar.

That includes forensic root-cause analysis, customer notification under state breach laws and the SEC cyber disclosure rules, OCC HAC and consent-order remediation, BSA/AML lookback reviews, and independent monitor or special-master roles when required. The goal is to leave the institution stronger, not just compliant.

Most engagements begin with a confidential 30-minute scoping call with senior personnel — at no cost — to understand the matter, the timeline, and the regulatory posture.

From there we propose a fixed-fee, hourly, or hybrid engagement letter, scoped against the relevant supervisory framework. Boards, GCs, CISOs, CSOs, CROs, and outside counsel can reach the team directly at +1 (855) 529-2466 or submit a case.