Sarah Shtylman

Sarah Shtylman advises innovators in the fintech and blockchain industries, and her clients range from entrepreneurs and startups to big tech and regulated financial institutions. With experience in both financial services regulatory issues and in transactional matters, Sarah counsels on a variety of regulatory, commercial, compliance, and product development projects—including non-fungible tokens (NFTs), regulated digital asset platforms, in-game currencies, and payment services integrations. She provides actionable regulatory assessments that drive product development, marketing, and regulatory licensing strategies. Sarah also drafts and negotiates the commercial agreements, vendor contracts, and terms of service that support her clients’ product launches. Sarah is well versed in state and federal financial services regulations, particularly related to payments and money transmission. She has advised clients through the application and compliance processes for state and federal trust charters, money transmission licensing and registration, and lending licenses. Sarah has engaged directly with state and federal regulators to discuss the applicability of various financial services regulatory regimes to emerging blockchain technology platforms and protocols that her clients are developing. Sarah also frequently supports her clients in matters related to marketplace payments, the issuance of application-specific virtual currencies, points and rewards programs, stored value devices, and other in-app value systems or payment mechanisms. On behalf of multiple international companies, Sarah has negotiated co-brand card deals, buy-now-pay-later (BNPL) payments integrations, and other significant payment processing arrangements. She represents both investors and emerging companies in financings, particularly on diligence questions related to payments integrations and money services regulatory concerns.