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Biography

Max Bonici is an Associate in the Washington, D.C., office of Buckley LLP, where he represents financial institutions and financial services providers on a wide range of regulatory, compliance, transactional, and enforcement matters.

Mr. Bonici advises clients on core bank regulatory issues and related matters involving the Federal Reserve, Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and the Consumer Financial Protection Bureau (CFPB), among others. He regularly helps financial institutions, affiliates, partners, and financial services providers navigate legal questions stemming from key bank regulatory laws and regulations, including questions of powers and permissible activities, the Bank Holding Company Act, control and related considerations, the Dodd-Frank Act generally, including exclusions from the Volcker Rule, the Bank Secrecy Act and anti-money laundering (BSA/AML) compliance, as well as OFAC and U.S. economic sanctions compliance and remediation, vendor management, and cryptocurrency, digital asset, and fintech issues more broadly.

His representative matters include:

  • Advising on and managing regulatory applications for financial institutions, their holding companies, and affiliates
     
  • Responding to civil investigative demands and other investigations, handling matters involving confidential supervisory information, and conducting internal investigations and voluntary self-disclosures to bank regulators, the CFPB and OFAC
     
  • Assisting non-U.S. banks with U.S. entry, including the establishment of U.S. branches and advising on options for fintechs and other nonbank financial services providers
     
  • Conducting deal due diligences with respect to financial regulatory issues, including control issues, and BSA/AML requirements
     
  • Advising on the remediation of supervisory issues and revision of policies and procedures
     
  • Conducting institution-wide compliance inventories in connection with remediation of supervisory concerns
     
  • Advising on supervisory expectations and contract requirements concerning vendor management issues
     
  • Advising litigation teams on bank regulatory and supervisory expectations
     
  • Counseling banking organizations on cross-border questions involving U.S. regulatory obligations and supervisory standards in conjunction with those of various non-U.S. counterparts
     
  • Analyzing how digital assets may be treated under applicable state and federal laws

Mr. Bonici currently serves as vice-chair of the American Bar Association’s subcommittee on enforcement (Banking Law).

Prior to joining Buckley, Mr. Bonici was an Associate at White & Case LLP. He received his J.D. and B.A. (summa cum laude, Phi Beta Kappa) from the George Washington University in 2014 and 2007 respectively.