Max Bonici

Counsel
Max Bonici

Max Bonici counsels U.S. and non-U.S. financial institutions and financial services providers on regulatory, supervisory, and enforcement matters. Max represents clients in prudential bank regulatory matters, applications and other filings, and powers/structure questions before U.S. bank regulators and in U.S. and cross-border internal investigations and due diligences. He counsels clients on enhancing policies and procedures and implementing remediation steps. Max regularly works on matters involving the Bank Holding Company Act, the International Banking Act, the National Bank Act, and the Dodd-Frank Act, including the Volcker Rule, among others. He also counsels emerging fintech and other tech companies on bank regulatory matters.

Max represents U.S. and non-U.S. financial institutions, their non-bank affiliates, vendors, and other financial services providers on U.S. financial laws and core bank regulatory issues, involving the Federal Reserve, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Consumer Financial Protection Bureau (CFPB), and state banking regulators.

He counsels clients on issues involving powers and permissible activities, structure and control, charter choice and conversions, Volcker Rule compliance, branching, affiliate transactions, third-party relationships, crypto and digital assets, bank-fintech partnerships and vendor issues, FDIC deposit insurance applications and coverage issues, FDIC recordkeeping requirements, passthrough insurance, and advertising rules.

Max also advises and manages regulatory applications for de novo institutions and activities, bank holding companies, business combinations, controlling and non-controlling equity investments, charter conversions, U.S. entry options for non‑U.S. financial institutions, including the establishment of U.S. branches and representative offices, and licensing and compliance considerations for fintechs and technology companies, bank partners, and non-bank financial services providers.

Prior to private practice, Max worked at the FDIC and the International Monetary Fund (IMF).

Max also serves as general counsel to Women in Housing and Finance, a premier, nonpartisan association of women and men that actively promotes its members in the fields of housing and financial services while retaining a focus on its female members.

Experience

Representative Matters

  • Advising on and managing regulatory applications and other filings for financial institutions, their holding companies, and affiliates
  • Conducting control analyses under the Federal Reserve’s control and controlling influence framework
  • 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
  • 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
  • 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 drafting and revising policies and procedures
  • Advising on appeals of supervisory ratings and findings
  • 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 digital assets under applicable state and federal laws

Insights

Credentials
+

Education

  • J.D. George Washington University Law School 2014
  • B.A. International Affairs summa cum laude George Washington University 2007

Bar Admissions

  • District of Columbia
  • New York

Professional Memberships and Activities

  • Co-chair, Subcommittee on Enforcement, American Bar Association’s Banking Law Committee
  • General counsel, Women in Housing and Finance

Recognition
+

  • Legal 500, Finance – Financial Services Regulation, 2024