Sarah Shtylman

Sarah Isabelle Hody Shtylman counsels clients at the intersection of regulatory, commercial, compliance, and product development matters for fintech and blockchain projects. She supports firms that seek to obtain or maintain trust bank charters, or licenses for payments and lending activities, by advising on structure, compliance, documentation, and engagement with federal and state regulators. Sarah also advises clients developing products and services that do not require regulatory oversight by counseling on product deployment, disclosures, commercial terms, and strategic negotiations. 

Sarah handles matters involving stablecoin issuance and reserve management, regulated digital asset custodians and exchanges, licensed payment platforms, asset-backed blockchain tokens, and non-fungible tokens. She also leads matters involving payment services integrations, marketplace payments, content monetization, in-game currencies, and other embedded finance service offerings. Sarah provides regulatory assessments that inform product development, marketing, and regulatory licensing strategies. She also drafts and negotiates commercial agreements, vendor contracts, financial services white-label arrangements, and terms of service that support clients’ product launches. 

Sarah is experienced in state and federal financial services regulations, including those related to digital asset custody and exchange, payments, and money transmission. She has advised clients through the application and compliance processes for state and federal charters, money transmission licensing and registration, and lending licenses. Sarah has engaged directly with state and federal regulators on the applicability of various financial services regulatory regimes to emerging blockchain technology platforms and protocols. 

Sarah also advises on marketplace payments, application-specific virtual currencies, points and rewards programs, stored value devices, and other in-app value systems or payment mechanisms. For international companies, she has negotiated co-brand card deals, buy-now-pay-later payments integration, and other significant payment processing arrangements. She also supports clients in financings, including diligence questions related to digital assets, payments, and money services regulatory concerns.