Navigating Proposed AML/CFT Rule Changes: New Supervision and Enforcement Frameworks

Ms. Capone is of counsel in the Washington, D.C. office of Gibson, Dunn & Crutcher. She is a member of the White Collar Defense and Investigations, Financial Regulatory, FinTech and Digital Assets, and Anti-Money Laundering Practice Groups. Ms. Capone's practice focuses on advising multinational corporations and financial institutions on Bank Secrecy Act/anti-money laundering (BSA/AML), anti-corruption, sanctions, payments, and consumer financial regulatory and enforcement matters, with a particular focus on regulatory matters impacting banks, casinos, social media and gaming platforms, marketplaces, fintech, payment service providers, and digital assets businesses. She regularly advises clients on the implementation, enhancement, and assessment of their compliance programs and internal controls and on platform terms and conditions, including Terms of Service, Merchant Agreements, Sales Agreements, Payment and Refund Policies, and Payment Service Provider Agreements. Ms. Capone frequently provides clients with training on financial services regulations and corporate compliance programs, including enforcement trends, industry best practices, and regulator expectations. She has been featured as a fintech “Rising Star” by Law360 in its 2023 publication of “attorneys under 40 whose legal accomplishments belie their age.” She has also been recognized by Super Lawyers as a 2022 and 2023 White Collar Defense “Rising Star.” In addition, Ms. Capone was recognized for her White Collar Litigation and Investigations work in the 2023 Lawdragon 500 X – The Next Generation edition, an inaugural guide highlighting attorneys “who will define where the legal profession of our country goes” and whose “leadership will be called upon by businesses and individuals when they face their crossroads.”

Ms. Charlton's practice focuses on consumer financial services and regulatory and compliance matters for banks, fintechs and non-bank businesses partnering with banks or other financial institutions to provide financial services to their customers. She advises on a wide range of topics including regulatory relations and examination management, consumer facing documents and agreements, licensing requirements on the state and federal level, Anti-Money laundering and sanction programs. Ms. Charlton brings over 39 years of experience in the financial services industry, with more than 34 years specializing in compliance, legal, and risk management. Before joining Frost Brown Todd, she served as Head of Compliance at a regional bank, where she led regulatory oversight, risk mitigation, and enterprise-wide compliance initiatives.

Mr. Stipano provides assistance in establishing, maintaining and monitoring anti-money laundering / countering the financing of terrorism (AML/CFT) compliance programs, conducts investigations and represents clients in regulatory matters, including state and federal regulatory enforcement actions. His regulatory and enforcement experience includes more than 30 years at the Office of the Comptroller of the Currency (OCC). As Deputy Chief Counsel from 2000 to 2016, Mr. Stipano played a key role in significant Bank Secrecy Act (BSA) rulemakings and policy issuances and oversaw major OCC enforcement actions. Prior to that, he served as the Director of Enforcement. Mr. Stipano has testified six times before Congress on enforcement and AML/CFT matters. He is a member of the advisory boards of ACAMS and the ABA/ABA Financial Crimes Enforcement Conference.