MARINA OLMAN-PAL

Corporate | Financial Regulatory & Compliance | Banking & Financial Services | Latin America Practice | Blockchain & Digital Assets | Environmental, Social & Governance (ESG) | Fintech

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 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, and compliance with 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 gaming 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
  • Bank and MSB formation, licensing, acquisitions and divestitures
  • Bank regulatory compliance counseling
  • FinTech/digital payments regulatory compliance
  • Blockchain & digital assets regulatory compliance
  • Bank Secrecy Act compliance guidance
  • Anti-Money Laundering
  • Sanctions compliance guidance

Experience

Publishable Matters

  • Represented Associated Foreign Exchange, Inc., a leader in global payment solutions and foreign exchange risk management, as financial regulatory counsel in its sale to FleetCor Technology, Inc, a leading global business payments company serving businesses, merchants and partners in North America, Latin America, Europe and Asia Pacific.
  • Represented Five Flags Banks, Inc. as financial regulatory counsel 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.
  • Represented Paysafe, a multinational online payments company, as M&A and financial regulatory counsel in its $441 million acquisition and integration of SafetyPay, an ecommerce payment platform operating in Latin America.
  • Represented PaySafe Group as U.S. financial regulatory counsel in connection with the acquisition of Openbucks, a California-based payments gateway that allows online merchants to accept gift cards as an alternative to credit cards for purchases.
  • Represented GoDaddy Inc., a web hosting and domain registration services company, as U.S. financial regulatory counsel in its acquisition and integration of Poynt Financial LLC, an all-in-one payment platform.
  • Represented GoDaddy Inc. as U.S. financial regulatory counsel in its acquisition of DAN.com, a domain marketplace platform with worldwide operations.
  • Represented BNP Paribas, a leading European bank, as financial regulatory counsel in the establishment and opening of the BNP Paribas Global Markets office in Miami, Florida.
  • Represented Volkswagen Financial Services as U.S. financial regulatory counsel in the sale of PayByPhone, a global provider of digital parking payment solutions to FLEETCOR Technologies, Inc., a leading global business payments company.

Speaking Engagements

Recognition & Leadership

Awards & Accolades

  • Listed, The Legal 500 United States
    • Finance – Financial Services Regulation, 2023
  • Listed, The Legal 500 Latin America Guide, Latin America: International, 2023-2024
    • Banking & Finance, 2023-2024
    • City Focus – Miami, 2024
  • Listed, The Best Lawyers in America
    • FinTech Practice, 2025
    • Corporate Law, 2023-2024
  • Selected, CrossTech magazine, “Industry Leader,” 2022
  • 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

Professional & Community Involvement

  • Member, Financial & International Business Association (FIBA) Board of Directors
  • Chair, Financial & International Business Association (FIBA) Legal and Regulatory Affairs Committee
  • Member, CrossTech Regulatory and Compliance Committee

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

11.12.24 Reminder: Comments to FDIC’s Proposed Brokered Deposit Rule Due Nov. 21 | GT Alert
10.10.24 FDIC Proposes New Requirements for Custodial Accounts | GT Alert
09.26.24 CTA Countdown: Upcoming FinCEN Filing Deadlines | GT Alert
08.27.24 FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements | GT Alert
07.12.24 FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements | GT Alert
06.14.24 California Senate Passes State’s Version of Corporate Transparency Act | GT Alert
05.30.24 New Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial Institutions | GT Alert
04.11.24 FinCEN Proposes Rule to Subject Certain Investment Advisers to Anti-Money Laundering Program, Recordkeeping, and Reporting Requirements under the Bank Secrecy Act | GT Alert
03.22.24 New Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial Institutions | GT Alert
03.07.24 District Court Declares Corporate Transparency Act Unconstitutional | GT Alert
03.05.24 FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements | GT Alert
02.14.24 Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities | GT Alert
01.24.24 FDIC Issues Cease and Desist Letters to 5 Entities for Making False or Misleading Representations Regarding Deposit Insurance | GT Alert
01.19.24 FinCEN Publishes Final Rule on Access to Beneficial Ownership Information | GT Alert
01.18.24 Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements | , GT Israel Law Blog | Blog
01.16.24 5 Trends to Watch: 2024 Blockchain | Published Article
01.11.24 Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements | GT Alert
01.09.24 Year-End 2023 Delaware Corporate and M&A Law Update | GT Alert
12.15.23 FinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective Date | GT Alert
12.12.23 New Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account Access | GT Alert
11.30.23 FinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies | GT Alert
11.09.23 CFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers | GT Alert
11.06.23 California Enacts Digital Assets Licensing Law | GT Alert
11.03.23 FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing | GT Alert
10.06.23 Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements | GT Alert
10.04.23 NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist | GT Alert
08.14.23 Federal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large Banks | GT Alert
05.04.23 UPDATE: Florida Gov. Signs Into Law Legislation Impacting ESG Initiatives of Financial Businesses Operating in Florida | GT Alert
04.28.23 Early 2023 Delaware Corporate and M&A Law Review | GT Alert
04.26.23 Florida Senate Passes Legislation Impacting ESG Initiatives of Financial Businesses Operating in Florida | GT Alert
04.25.23 Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights | GT Alert
04.25.23 The 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties | GT Alert
03.29.23 The 2023 Banking Crisis: Guidance for Private Investors Seeking to Acquire or Invest in Assets of Failed Insured Depository Institutions | GT Alert
03.16.23 The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties | GT Alert
03.13.23 Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities | GT Alert
03.10.23 Florida Considers Legislation That Could Impact Environmental, Social, and Corporate Governance (ESG) Initiatives of Financial Institutions | GT Alert
02.06.23 Delaware Court of Chancery Determines that Corporate Officers Owe Duty of Oversight: Practical Considerations | GT Alert
02.01.23 Anti-Money Laundering (AML) Whistleblower Provision Expanded to Cover Economic Sanctions Violations, Increase Incentives for Reporting | GT Alert
02.01.23 Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations | GT Alert
01.24.23 FinCEN Proposes Rule on Access to Beneficial Ownership Information | GT Alert
12.16.22 Danske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls | GT Alert
12.01.22 Lessons From Bittrex’s Settlements With OFAC And FINCEN | , Law360 | Published Article
10.26.22 Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act | GT Alert
10.19.22 Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations | GT Alert
10.13.22 ENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service Providers | GT Alert
09.02.22 Tornado Cash Sanctions May Signal Enforcement Shift, Law360
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

11.19.24 “Federal and State Law Regulations for Cross-border Crypto” ; “Compliance Officers Discussion Forum: The AI Revolution in Cross-Border Compliance: Innovations and Challenges”, , CrossTech World 2024
10.02.24 Charting the Course: Financial Regulation in Brazil’s Gaming Sector, Moderator, , Legal 500 GC Summit Brazil 2024
10.02.24 Charting the Course: Financial Regulation in Brazil’s Gaming Sector, Speaker, , Legal 500 GC Summit Brazil 2024
06.17.24 Speaker, Financial Crime and Banks: AML and AI in 2024, Financial Crime and Banks: AML and AI in 2024
05.23.24 Compliance Discussion Forum: Crypto Fintechs and Cross-Border Payments, Moderator, CrossTech Fintech Payments Conference 2024
04.18.24 Panelist, “Navigating Regulatory, Investment and Commercial Considerations for FinTech Founders and Investors, eMerge Americas 2024
03.18.24 ESG Breakfast, Financial & International Business Association (FIBA) AML Conference 2024
03.18.24 The Corporate Transparency Act, Speaker, Financial & International Business Association (FIBA) AML Conference 2024
02.07.24 Moderator, FIBA – Legal & Regulatory Affairs (LARA) Committee Event: Regulatory Events to Watch in 2024, FIBA – Legal & Regulatory Affairs (LARA) Committee Event: Regulatory Events to Watch in 2024
11.30.23 State of Regulation for Open Banking, Moderator, 2023 Open Banking Latam Conference
11.30.23 The State of Regulation and RegTech, Speaker, 2023 Open Banking Latam Conference
11.30.23 The State of Regulation Open Banking, Moderator, 2023 Open Banking Latam Conference
11.14.23 Panelist, Compliance Officers Discussion Forum: Insights for Compliance Officers Exploring the Impact of FedNow on Cross-Border Payments, CrossTech World 2023
11.14.23 Moderator, Compliance Officers Discussion Forum: Optimizing Compliance: Best Practices and Strategies for Partner Due Diligence in Cross-Border Payments, CrossTech World 2023
11.14.23 Panelist, Compliance Officers Discussion Forum: Compliance Evolution, Exploring the Role of KYC and KYB in Shaping Cross-Border Payment Regulations, CrossTech World 2023
10.20.23 The Corporate Transparency Act – Are You Ready?, Presenter, The Corporate Transparency Act – Are You Ready?
09.14.23 Presenter, Fintech Panel: Licensing and Regulatory Requirements, Miami Tech and Data Symposium: Navigating New Legal Risks in Data and Emerging Technologies
09.12.23 Panelist, FORO Análisis jurídico sobre el impacto de las normas AML en las relaciones de banca corresponsal, Congreso Latinoamericano de Derecho Financiero (COLADE) 2023
09.12.23 Panelist, Legal Analysis Forum – Impact of AML Regulations on Correspondent Banking Relationships, Congreso Latinoamericano de Derecho Financiero (COLADE) 2023
06.14.23 The Global Forum on Remittances, Investment and Development Summit 2023 & RemTECH Awards, Judge, Global Forum On Remittances, Investment And Development Summit 2023 & RemTECH Awards
06.13.23 Panelist, Keep the Cash Flowing: Regulatory Developments, Challenges and Opportunities for the Fintech/Payments Industry in 2023
05.30.23 Florida’s New anti-ESG Law and its Impact on Financial Businesses Operating in Florida, Speaker, Florida’s New anti-ESG Law and its Impact on Financial Businesses Operating in Florida
05.12.23 Compliance Officers Discussion Forum: US Regulation, Moderator, CrossTech Payments Conference 2023
03.23.23 From blockchain to crypto: there and back again, From Blockchain to Crypto: There and Back Again – Biennial IBA Latin American Regional Forum conference
03.13.23 The Anti-Money Laundering Act of 2020 – Where Do We Stand on the CTA?, Panelist; The Benefits and Challenges of Fintech Partnerships – Enhanced Scrutiny & Guidance on Fintech and Bank Partnerships/ KYC/AML for Non-Bank Financial Institutions Especially Payments Firms, Panelist, Financial & International Business Association’s (FIBA) Anti-Money Laundering Conference
03.13.23 Panelist, The Benefits and Challenges of Fintech Partnerships – Enhanced Scrutiny & Guidance on Fintech and Bank Partnerships, FIBA AML 2023 Conference
12.06.22 The Benefits and Challenges of FinTech Partnerships, Panelist, Financial & International Business Association (FIBA) LatAm Fincrime Conference 2022
11.15.22 Women in the Cross-Border Industry, Women Making a Difference in Fintech, Speaker; Compliance Officers Discussion Forum, Speaker, CrossTech World 2022
11.14.22 Panelist, How APIs Can Strengthen Integrated Service Offerings for Hispanics, Open Bank Latam – Building a New Open Bank Architecture in the Americas Hybrid Conference
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)