Introduction
Sam guides financial services clients at the leading edge of technology.
Sam Boro is a financial services and fintech lawyer who advises banks, fintech companies, merchants, and marketplaces on payments, digital assets, consumer financial regulatory compliance, and financial services innovation, including AI and cloud technologies.
Sam counsels clients on the development and launch of new payment products and services, including negotiating partnership agreements, designing compliant user experiences, and navigating regulatory frameworks. He provides actionable guidance under the Consumer Financial Protection Act; FTC Act; Equal Credit Opportunity Act and Regulation B, Regulation E, Regulation Z; the Fair Credit Reporting Act; the Gramm-Leach-Bliley Act, Durbin Amendment; and card network and NACHA rules.
His payments and fintech experience includes negotiating incentive agreements with card networks; structuring co-branded and private-label credit card programs with issuers; advising on money transmission regulatory strategies for gift cards, payroll, marketplaces, and payment facilitation; counseling on consumer lending obligations for installment and buy-now-pay-later products; and negotiating bank agreements for debit card programs, including crypto-to-fiat digital asset services. Sam also drafts anti-money laundering policies, terms of service, and cardholder agreements.
Sam advises financial institutions and enterprises on the regulatory and commercial dimensions of AI, machine learning, and hyperscale cloud services as they are subject to financial services regulation. His work includes responding to global regulators' requests for information on AI governance, developing internal AI policies, and counseling on customer-facing AI use cases.
Education & credentials
- American University Washington College of Law, J.D., cum laude, Senior Articles Editor, American University Law Review, 2014
- Elon University, B.A., Philosophy; International Relations, magna cum laude, 2007
- District of Columbia
- Maryland
- Alston & Bird LLP, Washington, D.C., Financial Services and Products Associate, 2017-2018
- Venable LLP, Washington, D.C., Banking and Financial Services Associate, 2014-2016; Summer 2013
Professional recognition
Recognized by Best Lawyers: Ones to Watch for Banking and Finance Law, 2023-2026
Latest thinking
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Blog
CLARITY’s crunch time: Senate draft seeks to settle familiar fights
August 04, 2026
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Legal development
Illinois enacts a broad licensing framework for buy now, pay later providers
July 29, 2026
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Legal development
New York's financial regulator turns its attention to agentic commerce
July 28, 2026
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Legal development
House Financial Services Committee advances earned wage access preemption bill
July 27, 2026
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Legal development
FSB Consultation on AI Sound Practices: Redundancy, Ambiguity, and the Path Forward
July 17, 2026
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Legal development
FinCEN's proposed CIP rule for permitted payment stablecoin issuers: Familiar doctrine, new frontier
July 07, 2026
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Legal development
The OCC's stablecoin issuer reporting playbook may not stay federal for long
July 01, 2026
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Legal development
FinCEN issues advisory on detecting illicit activity linked to unlawful employment: Implications for banks and MSBs
June 23, 2026
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Legal development Treasury Releases 2026 Report on Technologies Countering Illicit Finance Involving Digital Assets
April 01, 2026
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Legal development
GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins
June 27, 2025
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Blog
The Slow Death of the CFPB Open Banking Rule?
June 24, 2025
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Blog
What’s in Your (Crypto) Wallet? Executive Order on Digital Financial Technology
January 31, 2025
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