Jessica Romano focuses her practice on providing guidance to money transmitters, payments companies and other financial institutions on a variety of regulatory issues, including compliance with federal and state banking and consumer finance laws and multi-state licensing requirements, as well as transactional matters. She also advises private equity firms on transactional matters related to the acquisition and sale of payments companies and money transmitters. In addition, she has experience advising investment advisers and private funds on regulatory matters.


“CFPB Proposes Rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications,” Schulte Alert, Nov. 16, 2023

The Corporate Transparency Act: The Private Funds Guide to Compliance With the Beneficial Ownership Reporting Rule,” Schulte Alert, Nov. 2, 2023

“The Corporate Transparency Act: Key Considerations for Compliance With the Beneficial Ownership Reporting Rule,” Schulte Alert, Nov. 2, 2023

California Passes Portions of the Model Money Transmission Modernization Act,” Schulte Alert, Oct. 12, 2023

“Rising Star: Schulte Roth's Jessica Romano,” Law360, June 27, 2023 (featured)

FinCEN Identifies Bitzlato as a 'Primary Money Laundering Concern' in First-Time Use of Section 9714(a) and DOJ Charges Its Founder with Owning an Unlicensed Money Transmitting Business,” SRZ Alert, Feb. 3, 2023

NYDFS Releases Guidance for BitLicensees and Limited Purpose Trust Companies on Asset Custody in the Wake of Cryptocurrency Insolvencies,” SRZ Alert, Jan. 31, 2023

“NYDFS Announces $100 Million Settlement with Coinbase for AntiMoney Laundering Compliance Deficiencies,” SRZ Alert, Jan. 23, 2023

“Substantial Penalty Against Major Bank Highlights Aggressive CFPB Enforcement,” SRZ Alert, Dec. 21, 2022

“CFPB Proposes Rule to Establish Public Registry of Nonbanks with Consumer Financial Law Enforcement Orders,” SRZ Alert, Dec.19, 2022 

NYDFS Continues Effort to Amend Cybersecurity Regulation (“Part 500”) and Publishes Revised Proposed Amendments,” SRZ Alert, Nov. 23, 2022

“Financial Institutions Invited to Comment on CFPB’s Initial Sketch of New Consumer Data Rights Rule,” SRZ Alert, Nov. 3, 2022

CFPB Supports Broad Assertion of State Enforcement Power,” SRZ Alert, May 27, 2022

“CFPB Obtains $10 Million Penalty Against Major Bank Using Expansive UDAAP Authority,” SRZ Alert, May 11, 2022

“CFPB Invokes 'Dormant' Authority to Conduct Exams of Fintech Companies,” SRZ Alert, April 27, 2022

“FDIC Issues Letter on Crypto-Related Activities,” SRZ Alert, April 13, 2022

Federal Reserve Releases Report on Central Bank Digital Currency, SRZ Alert, Jan. 25, 2022

CFPB Authorizes Debt Collectors to Use Social Media, Text and Email, SRZ Alert, Dec. 20, 2021

CFPB Updates Electronic Fund Transfers FAQs, SRZ Alert, Dec. 16, 2021

“Federal Agencies Issue Joint Statement on Approach to Crypto-Asset Regulation for Banking Organizations,” SRZ Alert, Dec. 1, 2021

“OCC Outlines System for Banks to Engage in Certain Cryptocurrency Activities Subject to Supervisory Non-Objection,” SRZ Alert, Dec. 1, 2021

“FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” SRZ Alert, Nov. 30, 2021

“President’s Working Group Issues Interagency Risk Assessment of Stablecoins,” SRZ Alert, Nov. 8, 2021

“Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” SRZ Alert, Oct. 28, 2021

“Businesses with up to 15,000 Employees or $5 Billion in Revenue: Federal Reserve Expands Scope and Eligibility for Main Street Lending Program,” SRZ Alert, May 1, 2020

“Businesses with 10,000 or Fewer Employees: Federal Reserve Publishes Details on CARES Act Loans,” SRZ Alert, April 9, 2020

Paycheck Protection Program Update: Guidance on Affiliation, Clarification on Eligibility and New Forms,” SRZ Alert, April 6, 2020

“Federal Reserve Delays Effective Date of New, More Flexible ‘Control’ Rule for Six Months,” SRZ Alert, March 31, 2020

“CARES Act Provides Financial Assistance for Mid-Sized Companies,” SRZ Alert, March 30, 2020

“Summary of Proposed Volcker 2.0 for Fund Activities,” SRZ Memorandum, Feb. 6, 2020; republished in The Hedge Fund Journal, March 2020; republished in The Banking Law Journal, June 2020

Federal Reserve Provides Greater Clarity and Flexibility for Noncontrolling Investments in (and by) Banking Organizations,” SRZ Alert, Jan. 31, 2020; republished in The Banking Law Journal, June 2020

Agencies Publish Proposed Volcker 2.0 for Fund Activities,” SRZ Alert, Jan. 30, 2020

FDIC and OCC Approve Volcker 2.0 — Summary of Amendments to Fund Activity Provisions,” SRZ Alert, Aug. 23, 2019 (co-author); republished in Eurekahedge, October 2019

“FDIC Announces Multiple Actions To ‘Promote a More Transparent, Streamlined, and Accountable’ Process for Bank Applicants,” SRZ Alert, Dec. 6, 2018 (co-author)

Speaking Engagements

Bank Failures: High Level Overview and Considerations, Client Seminar, May 2023


  • Law360 — Rising Star, 2023

Prior Experience

  • Florio Leahy LLP/Orical LLC
  • Skadden, Arps, Slate, Meagher & Flom LLP