Max Bonici is an associate in the Financial Services Regulatory practice. He counsels US and non-US financial institutions on bank regulatory and enforcement matters.
Max represents financial institutions in licensing and regulatory matters before US bank regulators as well as in US and cross-border matters, including by conducting internal investigations and due diligence reviews. He also counsels clients on enhancing policies and procedures and implementing remediation steps. He regularly works on matters involving the Bank Holding Company Act, the International Banking Act, and the Dodd-Frank Act, among others. In addition, he counsels emerging fintech and regtech companies on regulatory matters.
Max has authored numerous insightful publications related to the legislative and regulatory challenges faced by financial institutions. He also is a key contributor to the Firm's Financial Regulatory and Legislative Dashboard, which provides periodic updates and insights for financial institutions, particularly as the COVID-19 response develops.
Max joined White & Case from another global law firm and he previously worked at the Federal Deposit Insurance Corporation and the International Monetary Fund.
Select experience includes:
Ways of entry into the US domestic market for non-US banks and other financial services providers
A non-US bank's financial holding company election
The merger of two bank holding companies of a non-US bank
Control issues and related remediation under the Bank Holding Company Act
The licensure of a federal branch of a non-US bank
The chartering of a state-licensed bank
Cross-border and US investigations involving the Department of Justice, the Federal Reserve, and the Consumer Financial Protection Bureau
US economic sanctions issues involved blocked property by US financial institutions and the application for a specific license from the Office of Foreign Assets Control
Large-scale bank regulatory compliance inventories in the context of supervisory actions
State licensure requirements for lending, money transmission, and other activities
"FinCEN and US Federal Banking Agencies Clarify Risk-Based Obligations on Politically Exposed Persons," FCCED, September 2020
"Regulators' Preemption Scuffle Offers Opportunities for Financial Services," Bloomberg Law, August 2020
"Bank Regulators' Proposals Won't Erase Madden Uncertainty," Law360, December 2019