BJ Sanford

BJ Sanford advises payments and fintech companies, U.S. and foreign banks, trade associations, investors, and policy and consulting firms. His practice centers on payments regulation, public policy, and the regulation of bank activities and structure. He also advises clients on regulatory capital, bank investments and control, affiliate transactions, the U.S. operations of foreign banks, and regulatory examinations.

• Payments regulation. BJ advises payments firms and banks on payment regulation, product development, and compliance with rules including Regulation E, Regulation Z, Regulation II (Durbin), and BSA/AML. He helps payments clients navigate emerging issues such as agentic commerce, fraud information sharing, payment system access, personalized pricing, fintech-bank partnerships, and payment stablecoins under the GENIUS Act.
• Public policy. BJ assists institutions and trade associations with public policy analysis and advocacy on payments, fraud prevention, digital assets, bank charters, deposit insurance, capital, administrative law, and other financial regulation issues.
• Bank charters and licensing. BJ represents companies seeking or contemplating bank charters and licenses, including national trust banks, ILCs, and limited-purpose state banks. His work covers charter selection, applications, conversions, acquisitions, powers, and preemption analysis.
• Bank activities and structure. BJ advises banking organizations on the regulations governing bank activities and structure, including transactions with affiliates under Sections 23A and 23B of the Federal Reserve Act and Regulation W, lending to insiders under Regulation O, permissibility of banking and non-banking activities and investments, and preemption and rate exportation under the National Bank Act and Federal Deposit Insurance Act.
• Bank investments and control. BJ counsels venture capital and private equity firms, individual investors, and bank holding companies on bank investments and control. He helps clients determine whether an investment creates control under applicable laws and to comply with requirements establishing non-control. He also assists investors with regulatory diligence, approvals, and agreement terms for bank investments, mergers, and acquisitions.
• Foreign banks. BJ advises foreign banks on entering and operating in the United States through branches and representative offices, including licensing, permissible activities, governance, and examinations, and on the state licensing limits that apply when they serve U.S. customers from abroad.
• Capital. BJ counsels clients on the application of bank regulatory capital requirements, including how particular assets and exposures are treated for capital purposes and the qualification of capital instruments for different capital categories.
• Supervision and enforcement. BJ helps banks prepare for and manage examinations, remediate supervisory findings, and respond to potential enforcement actions. He also designs exam-management functions and regulatory engagement policies.

As part of his practice, BJ leads the firm's efforts to use technology that expands our capacity to deliver greater value to clients faster and more efficiently. He builds many of the tools and artifacts we use to support our regulatory practice and empower clients with more useful work products. He also advises regulatory technology firms and the internal teams of financial institutions on regulatory inventories, regulation applicability, and regulatory change management.

BJ was previously a partner and managing director at Promontory, the financial services regulatory advisory firm, where he led the bank strategy and structure practice and the Promontory Obligations Library, as well as efforts to develop AI solutions for regulatory use cases. He was earlier an associate in the banking practice at Covington & Burling, and began his legal career as a clerk to the Hon. A. Raymond Randolph of the U.S. Court of Appeals for the D.C. Circuit.