MARINA OLMAN-PAL

Corporate | Financial Regulatory & Compliance | Banking & Financial Services | Latin America Practice | Blockchain & Digital Assets

Marina Olman-Pal, Shareholder at GTLaw, 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.

Concentrations

  • Financial services, regulatory and compliance
  • BSA/anti-money laundering and OFAC sanctions compliance guidance
  • Development of anti-money laundering and OFAC compliance programs
  • FinTech, blockchain, digital payments license and regulatory compliance guidance

Speaking Engagements

Experience

Representative Matters

  • Representation of Associated Foreign Exchange, Inc., a leader in global payment solutions and foreign exchange risk management, in connection with its sale of its money transmitter business to FleetCor Technology, Inc, a leading global business payments company serving businesses, merchants and partners in North America, Latin America, Europe and Asia Pacific.
  • Representation of Five Flags Banks, Inc. in the merger of two of its subsidiary Florida-chartered community banks, The Warrington Bank, a Florida banking corporation, and Bank of the South, a Florida banking corporation. The merger was an internal corporate reorganization.
  • Representation of GoDaddy Inc., a web hosting and domain registration services company, in connection with the acquisition and integration of Poynt Financial, an all-in-one payment platform.
  • Representation of GoDaddy Inc., a web hosting and domain registration services company, in connection with the acquisition of DAN.com, a domain marketplace platform servicing clients worldwide.
  • Representation of Paysafe, a multinational online payments company, in its $441 million acquisition of SafetyPay, an ecommerce payment platform. With this acquisition, Paysafe will be the leading open banking and eCash solutions provider in Latin America.
  • Represented PWCC Marketplace, LLC, PWCC Services, LLC and PWCC Vault, LLC in connection with their senior secured credit facilities in an amount up to $175 million from WhiteHawk Capital Partners, LP and Wingspire Capital LLC.

Recognition & Leadership

Awards & Accolades

  • Listed, The Best Lawyers in America, Corporate Law, 2023
  • Selected, National Law Review, “Go-To Thought Leader: Finance Law – Anti-Money Laundering Legislation,” 2021
  • Listed, Super Lawyers magazine, Florida Super Lawyers, “Rising Star,” 2009-2010

Credentials

Education

  • J.D., cum laude, American University Washington College of Law, 2006
  • B.S., cum laude, Biological Sciences, Florida International University, 2001

Admissions

  • Florida
  • District of Columbia

Languages

  • Spanish, Native

News, Insights & Presentations

Marina is a contributor to GT’s Financial Services Observer Blog

News

Insights

09.02.22 Tornado Cash Sanctions May Signal Enforcement Shift, Law360 | Published Article
08.19.22 Regulatory Scrutiny on the Rise of Bank and Crypto Company Dealings | GT Alert
08.12.22 OFAC Sanctions Cryptocurrency Mixing Service for Allegedly Facilitating Money Laundering | GT Alert
07.18.22 FinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export Controls | GT Alert
06.23.22 New York’s Proposed Moratorium on Cryptocurrency Mining Operations | GT Alert
06.22.22 NYDFS Becomes First US Financial Regulator to Issue Stablecoin Expectations to Virtual Currency Industry | GT Alert
06.22.22 The Responsible Financial Innovation Act: A Comprehensive Proposal to Regulate Digital Assets | GT Alert
05.26.22 Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the State | GT Alert
03.15.22 Executive Order on Digital Assets Establishes Policy Goals for Whole-of-Government Approach to Regulation | GT Alert
03.07.22 DOJ Establishes Task Force KleptoCapture to Enforce Sanctions, Export Restrictions in Response to Russia’s Invasion of Ukraine | GT Alert
02.08.22 Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency | GT Alert
01.14.22 FinCEN Proposes Rule on Beneficial Ownership Reporting Under Corporate Transparency Act | GT Alert
12.16.21 FinCEN Launches Rulemaking Process to Implement Reporting Requirements for Real Estate Sector | GT Alert
12.01.21 US Federal Banking Regulators Release Joint Statement on ‘Crypto-Asset Policy Sprint Initiative’ | GT Alert
11.23.21 President’s Working Group on Financial Markets Releases Report and Recommendations on Stablecoins | GT Alert
07.06.21 FinCEN Identifies New Anti-Money Laundering (AML) National Priorities | GT Alert
01.19.21 The Anti-Money Laundering Act of 2020: Congress Enacts the Most Sweeping AML Legislation Since Passage of the USA PATRIOT Act | GT Alert
12.29.20 FinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions | GT Alert
11.13.20 California’s Adoption of ‘Mini-CFPB’ Will Transform Consumer Financial Services Regulation in the State | GT Alert
10.29.20 FRB and FinCEN Propose Significant Amendments to Recordkeeping and Travel Rule Regulations | GT Alert
08.04.20 FinCEN Issues FAQs Regarding Customer Due Diligence Requirements, Financial Services Observer | Blog
07.10.20 FinCEN Alerts Financial Institutions to COVID-19-Related Imposter Scams and Money Mule Schemes | GT Alert
07.01.20 Federal government might take corporate transparency up a notch, South Florida Business & Wealth | Published Article
07.01.20 FinCEN Issues Guidance to Financial Institutions on Hemp-Related Due Diligence | GT Alert
05.20.20 FinCEN Publishes Advisory on Medical Scams Related to COVID-19 and Companion Notice with Filing Instructions for Financial Institutions | GT Alert
04.22.20 FFIEC Updates Its Bank Secrecy Act/Anti-Money Laundering Examination Manual | GT Alert
03.20.20 Bank Regulators Issue Joint Statements and Guidance in Response to Coronavirus Pandemic | GT Alert
03.20.20 New Jersey Considers A Licensing Framework for Digital Asset Business Activities | GT Alert
02.25.20 FinCEN Ruling Clarifies Currency Transaction Report (CTR) Filing Obligations of Financial Institutions | GT Alert
10.29.19 U.S. House Passes Bill That Would Require Disclosure of Beneficial Owners of U.S. Corporations and Limited Liability Companies | GT Alert
10.23.19 CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act | GT Alert
08.07.19 Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs | GT Alert
06.13.19 Florida Creates Blockchain Task Force to Study Benefits of Blockchain Technology | GT Alert
06.07.19 FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies | GT Alert
03.07.19 Blockchain & Cryptocurrency Newsletter – Winter 2019 | Newsletter
08.07.18 OCC To Begin Accepting National Bank Charter Applications from Financial Technology Companies | GT Alert
08.24.17 FinCEN Expands Residential Real Estate GTOs to Include Honolulu and to Require the Reporting of Real Estate Transactions Funded by Wire Transfer | GT Alert
08.17.17 New Bill Introduced in the U.S. Senate to Require the Disclosure of Ultimate Beneficial Owners of Corporations and LLCs Formed or Registered in the United States | GT Alert
03.02.17 High-End, Cash-Only Real Estate Sales in Six Major Metropolitan Areas Remain Subject to Mandatory AML Reporting Requirements | GT Alert
01.06.17 FinCEN Issues Guidance to Casinos Confirming that Suspicious Activity Reports May Be Shared with U.S. Parents and Affiliates | GT Alert

Presentations

09.22.22 Panelist on Digital Currencies – Applications/Implementation for CFOs, AS/COA CFO Forum: Mexico
06.17.22 Moderator, Panel Discussion II: Women Leading Crypto & Fintech- AS/COA Women’s Hemispheric Network Forum – Miami 2022, AS/COA Women’s Hemispheric Network Forum – Miami
06.10.21 Panelist, REGLIANCE 2021: At the Crossroads Between Compliance, Regtech and Regulation, REGLIANCE 2021: At the Crossroads Between Compliance, Regtech and Regulation
04.27.21 Moderator, State of Regulation in Latin America (Fintech, Remittances & Forex) , Virtual Event | International Money Transfer & Cross-Border Payments (IMTC) LATAM 2021
11.16.20 IMTC World: Cumplimiento y Supervisión en el corredor USA-Mexico, Speaker, IMTC World Virtual Conference
06.11.20 Life After COVID-19: FFIEC BSA/AML Exam Manual Updates, Speaker, Life After COVID-19: FFIEC BSA/AML Exam Manual Updates
04.21.20 Panelist, Florida International Bankers Association (FIBA): Lavado a Través del Sector Inmobiliario (English Title: Money Laundering through the Real Estate Sector) (Apr. 2020), Florida International Bankers Association (FIBA): Lavado a Través del Sector Inmobiliario (English Title: Money Laundering through the Real Estate Sector)