Digital Banking FAQ

Engage at the earliest credible signal of a strategic, regulatory, or technology shift — a digital transformation, an MRA 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 governance and risk frameworks, and avoid rework when products launch outside OCC Bulletin 2013-29 or FFIEC IT guidance.

We are practitioners at the intersection of law, technology, and financial services regulation. The team includes attorneys, former regulators, court-appointed special masters, blockchain forensics specialists, and security technologists who have advised banks, fintechs, exchanges, and boards through charter applications, BSA/AML build-outs, enforcement defense, and post-incident remediation.

We build the roadmap around business strategy, regulatory perimeter, and technology architecture — sequenced so each milestone is defensible to the board, regulator, and customer. The roadmap addresses target operating model, core modernization, channel strategy, data and analytics, and the regulatory build (BSA/AML, CFPB UDAAP, fair lending, Reg E, FFIEC cyber, NYDFS Part 500).

We treat every BaaS or fintech partnership as a third-party risk and supervisory exposure for the bank. Work covers due diligence under OCC Bulletin 2013-29 and the 2023 Interagency Guidance on Third-Party Relationships, BSA/AML and OFAC program ownership, Reg E disputes, CFPB UDAAP review, and ongoing oversight and exit planning.

An effective program covers the FFIEC BSA/AML Examination Manual pillars — internal controls, independent testing, BSA officer, training, CDD, and beneficial ownership — calibrated to products, customers, geographies, and channels, with transaction monitoring tuned to RTP, FedNow, Zelle, and ACH, plus OFAC screening and NYDFS Part 504 certification where applicable.

We map every consumer-facing flow against UDAAP, Reg E, ECOA/Reg B, TILA/Reg Z, and CFPB guidance on junk fees, fraud-induced transfers, and AI decisioning. Where ML is used in underwriting or fraud, we build adverse action logic, SR 11-7 model risk management, and disparate-impact testing into the SDLC.

CSOs and CROs need an outside team that can stand up frameworks, defend them to examiners, and run them during incidents or enforcement actions. We deliver programs aligned with FFIEC CAT, NIST CSF 2.0, NYDFS Part 500, ISO 27001, and the SEC cyber disclosure rules, plus 24/7 incident response, board reporting, and tabletops.

We build the legal and operational rails — money transmission, BSA/AML, sanctions, custody, market structure, and consumer protection — for blockchain and digital asset products. Engagements cover FinCEN MSB registration, the FATF Travel Rule, NYDFS BitLicense, Wyoming SPDI, SEC vs CFTC jurisdictional analysis, stablecoin reserves, and on-chain forensics.

Real-time payments and open banking compress decision windows from days to seconds, requiring continuous controls. We help institutions build fraud, sanctions, and authorization frameworks for FedNow and RTP, design CFPB Section 1033 open banking controls, and assess CBDC and tokenized deposit pilots.

Retain an expert when the dispute turns on industry standard of care, regulatory interpretation, or technical fact-finding the trier of fact cannot evaluate alone. Typical engagements include BSA/AML and OFAC adequacy, Reg E disputes, cyber-incident liability, blockchain transaction tracing, model risk, fiduciary duty, and FINRA, SEC, and CFTC enforcement matters.

We train at the board, executive committee, and operational staff levels. 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, in person, virtually, or hybrid, with CLE credit where relevant.

We move in within hours, run the technical and legal investigation under privilege, and build remediation that satisfies the board, regulator, and plaintiffs' bar. That includes forensic root-cause analysis, customer notification under state and SEC rules, OCC HAC and consent-order remediation, BSA/AML lookback reviews, and independent monitor roles.