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Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks

By Marina Olman-Pal, Jera L. Bradshaw, Kyle R. Freeny, Nathan M. Iacovino & Catherine Yepes on May 16, 2025
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The Board of Governors of the Federal Reserve System (Board) has withdrawn supervisory guidance for Board-supervised banks concerning crypto-asset and dollar token activities and Board expectations for these activities. The Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) also withdrew joint supervisory statements on crypto-asset activities and exposures.

Continue reading the full GT Alert.

Photo of Marina Olman-Pal Marina Olman-Pal

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 and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

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 and compliance 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, GENIUS Act and 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 non-financial services companies considering new payment or digital wallet models. 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.

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Photo of Jera L. Bradshaw Jera L. Bradshaw

Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory

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Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory compliance, bank-fintech partnerships, regulatory applications, enterprise risk; and “troubled” banks.

Jera regularly assists financial institutions of all sizes with examinations, applications, and enforcement matters; has an extensive background advising banks on compliance and remediation programs; and is experienced appearing before the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Consumer Financial Protection Bureau (CFPB), and multiple state bank regulatory authorities.

Before joining private practice, Jera served ten years as bank regulatory counsel to the FDIC and the Tennessee Department of Financial Institutions (“TDFI”) where she conducted legal review of regulatory filings such as branch applications, golden parachute payments, mergers, brokered deposit waivers, changes in bank control, and retirement of capital; supported regulatory examinations; oversaw enforcement actions; and advised on legislation, laws, and policies affecting financial institutions.

More recently, she acted as senior counsel of regulatory affairs for a large regional bank advising on intricate legal issues affecting the enterprise including implementation of enhanced prudential standards, affiliate transactions, dividend restrictions, Community Reinvestment Act strategy, and consumer compliance management systems (“CMS”).

Jera leverages her deep bank regulatory experience to deliver practical legal advice on a range of financial regulatory topics including affiliate transactions, deposit products, BSA/AML compliance, lending limits, insider transactions, capital and liquidity risk management, and the Community Reinvestment Act. She counsels clients on regulatory aspects of new product development, including bank partnership models, BaaS relationships, payment systems, fintech deposit platforms and third-party oversight. She also advises bank acquirers and sellers on regulatory approvals for M&A transactions, noncontrolling investments, nonbank activities, and other complex issues.

Jera is chair of the American Bar Association’s Regional and Community Banks Subcommittee, a faculty member of Fundamentals of Banking Law, and a guest lecturer at the SMU Dedman School of Law. In addition to speaking on regulatory issues affecting insured depository institutions, Jera is routinely called upon to train bank boards and management on a wide range of legal and risk management topics.

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Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to

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Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section (MLARS), draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action.

While at the Department of Justice, Kyle also played a key role in major international money laundering and corruption matters, including important matters involving the Bank Secrecy Act (BSA) and Foreign Corrupt Practices Act (FCPA). Kyle also has considerable experience handling sensitive and complex cross-border issues in transnational financial cases, and she was responsible for the largest civil asset forfeiture recovery in DOJ history.

Kyle uses this deep experience in federal law enforcement to counsel clients facing scrutiny from DOJ, the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), and other law enforcement and financial regulatory agencies. Kyle conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.

Kyle also helps clients develop and litigate challenges to federal regulations, policies, and agency decisions across a range of industries, drawing on her years of prior experience at DOJ representing a cross-section of federal agencies —from the Office of Foreign Assets Control (OFAC) to the Department of Energy to the Department of State and various intelligence agencies—in high-profile litigation. She has appeared before federal trial courts across the country.

Read more about Kyle R. FreenyKyle's Linkedin Profile
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Photo of Nathan M. Iacovino Nathan M. Iacovino

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and

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Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and implementation of domestic and global custody, fund administration, managed account platforms, collateral management, and related servicing arrangements by and among his custodial, investment servicing and managed account platform provider clients and their respective fund, investor, pension plan, and adviser client base.

Nathan also represents mutual fund complexes, asset managers, investment advisers, institutional investors and financial institutions in developing and maintaining financial products while navigating the regulatory landscape.

Nathan’s clients include a wide range of private funds, registered investment companies, transfer agents, banks, financial institutions, institutional investors and investment advisors.

Read more about Nathan M. IacovinoNathan's Linkedin Profile
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Photo of Catherine Yepes Catherine Yepes

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement…

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), Florida Office of Financial Regulation (OFR), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC).

Catherine advises clients on Bank Secrecy Act compliance, with an emphasis on anti-money laundering issues. She handles business, licensing, regulatory, and compliance matters for financial institutions. Her work includes performing independent risk assessments, developing anti-money laundering and sanctions compliance programs, preparing voluntary self-disclosures and specific license applications for submission to OFAC, and assisting with enforcement actions and subpoenas. Catherine also drafts, negotiates, and reviews commercial agreements and terms and conditions.

Catherine previously served as a Staff Attorney at the Third District Court of Appeal in Miami, where she analyzed trial records, researched legal principles, attended oral arguments and assisted in drafting opinions. She also gained experience in appellate litigation during her time as an academic intern with the Supreme Court of Florida in Tallahassee.

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  • Posted in:
    Technology
  • Blog:
    Overheard on the Block(chain)
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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