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Dan Stipano brings more than three decades of bank regulatory and enforcement experience to his position as a Partner in Buckley LLP’s Washington, D.C., office. In his practice he advises on all aspects of bank regulatory and compliance issues, represents clients in state, federal, and foreign banking enforcement actions, and provides assistance in establishing, maintaining, and monitoring Bank Secrecy Act and Anti-Money Laundering (BSA/AML) compliance programs.

Prior to joining the firm, Mr. Stipano was at the Office of the Comptroller of the Currency (OCC), where he served as Deputy Chief Counsel for 16 years and Director of the Enforcement & Compliance Division after joining the agency as a staff attorney 30 years ago. In his role as Deputy Chief Counsel, including serving two stints as Acting Chief Counsel, he was extensively involved in every major OCC enforcement action over the last 20 years until the time of his departure. In addition, he played a key role in every major BSA/AML post-USA PATRIOT Act rulemaking and policy issuance.

His recent work includes:

  • Representing a bank in an Office of Foreign Assets Control (OFAC) investigation resulting in issuance of a cautionary letter
  • Advising a bank on regulatory expectations with respect to its proposed partnership with a major online retailer
  • Advising a bank with respect to its response to a 15-day letter in a Federal Deposit Insurance Corporation (FDIC) civil money penalty (CMP) proceeding
  • Drafting and negotiating a contract concerning AML and OFAC responsibilities between a national bank and a credit card network access and service provider
  • Advising a national bank with respect to a 15-day letter response in a CMP proceeding concerning unfair or deceptive acts or practices (UDAP)
  • Advising a bank concerning its policies, procedures, and controls with respect to a customer’s business activities in Cuba
  • Drafting BSA/AML policies and procedures for a federal branch of a foreign bank, a broker-dealer, and a blockchain-based consumer lender
  • Providing legal advice to a Federal Branch of a foreign bank with respect to the OCC’s assessment of a $12.5 million CMP and issuance of a cease and desist order based on BSA violations
  • Submitting requests to the Financial Crimes Enforcement Network (FinCEN) for exceptive relief from certain requirements of the CDD Rule on behalf of the Mid-Size Bank Coalition of America, and a group of 15 banks

Over the course of his career at the OCC, Mr. Stipano oversaw three Supreme Court cases that resulted in victories for the agency and the banking industry, supervised more than a dozen successful appeals of lower court decisions, and was instrumental in bringing the first fair lending action taken against a bank by a federal banking agency, as well as the first UDAP action taken against a bank. Mr. Stipano has testified before Congress six times on enforcement and BSA/AML matters, and prepared dozens of OCC witnesses to do the same.

A recognized leader in his field, Mr. Stipano has spoken at more than 100 conferences and industry events, and over the course of his career has established strong working relationships with his former colleagues in law enforcement and in other regulatory agencies. He received his J.D. from the College of William & Mary and his B.A. from Union College.

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Awards and Recognitions

Awards & Recognitions

  • Best Lawyers 2019-2020: Banking and Finance Law, Litigation - Banking and Finance, Financial Services Regulation Law 


  • J.D., College of William & Mary
  • B.A., Union College


  • District of Columbia
  • Virginia
  • U.S. Supreme Court

Government Service

    • Deputy Chief Counsel, Office of the Comptroller of the Currency; two stints as Acting Chief Counsel

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