Audrey advises FinTech clients on a wide range of banking, payments and financial services issues.
Overview
Audrey focuses her practice on guiding clients through complex regulatory and compliance matters involving financial services, payment systems and virtual currency. She assists financial institutions and financial technology (FinTech) companies, including money transmitters, digital asset/virtual currency/cryptocurrency-related businesses, prepaid card issuers, online marketplace providers and online content/gaming platforms, in addressing regulatory and contractual matters.
Audrey works closely with clients to bring novel financial products and services to market—advising from product inception to launch and thereafter as new considerations arise.
Audrey provides guidance in connection with the implementation of compliance programs addressing anti-money laundering and OFAC sanctions laws/regulations, state money transmission and virtual currency business activity laws, the Dodd-Frank Wall Street Reform and Consumer Financial Protections Act, the Electronic Fund Transfer Act/Regulation E, the Prepaid Access Rule, the Gramm-Leach-Biley Act/Safeguards Rule, and regulations promoting open banking.
Experience
- Assists businesses in a variety of industries with obtaining money transmitter and virtual currency business activity licenses nationwide, as well as alternatively structuring the services and relationships with financial institution partners to bring products and services to market and scale.
- Develops compliance programs for bank service providers and money transmitters, including anti-money laundering and information security compliance programs.
- Advises clients on the structuring of complex stored value/prepaid card arrangements to bring products to market and provide clarity on regulatory obligations.
- Provides strategic guidance on the structuring of in-game virtual currency and rewards programs.
- Drafts terms of service and other customer-facing documentation in support of financial service product offerings.
- Advises persons engaged in virtual currency business activities on compliance with emerging payments laws/regulations, including anti-money laundering requirements, and novel licensing regimes.
- Assists and provides strategic advice to support licensed financial services companies or prospective acquirers of such companies navigate the change in ownership process.
- Provides white-glove service to prospective officers/directors of licensed financial institutions to facilitate smooth transitions to such roles in compliance with regulatory requirements.
News & Insights
News
Publications
"Visa's Agentic Payment Rules Expose Compliance Tensions," Law360, May 2026
"OCC Rule Tests Nonfiduciary Powers of Trust Banks," Law360, March 2026
"Leaning Into Discomfort: Embracing New Opportunities Can Foster Growth," The Legal Intelligencer, October 2025
"Where Payments Law And Regulation Are Headed In 2025," Law360, January 2025
"NY's Revamped Card Surcharge Ban Is Unique Among States," Law360, February 2024
"The Other Side of the (Bit)Coin: Solutions for the United States to Mitigate the Energy Consumption of Cryptocurrency," George Washington Journal of Energy and Environmental Law, May 2021
Speaking Engagements
Payments Law Update, Hot Topics and Trend Outlook for 2025, October 2024
Professional & Civic Activities
Professional & Civic Activities
District of Columbia Bar
Practices & Industries
Admissions
- District of Columbia
Education
The George Washington University Law School, J.D., with high honors, 2021
- Order of the Coif
- George Washington Journal of Energy and Environmental Law
University of Florida, B.A., Economics and Political Science, minor in Agricultural and Natural Resource Law
- Anderson Scholar
