Sarah (Hody) Shtylman

Sarah Shtylman counsels clients on regulatory, commercial, compliance, and product development matters for fintech projects. She supports firms that seek to obtain or maintain financial services licenses, charters, and registrations by advising on structure, compliance programs, documentation, and engagement with regulators. For clients that seek to build products and services that do not require such regulatory oversight, Sarah provides support on product deployment, required disclosures, commercial terms, and strategic negotiations. Sarah handles matters involving regulated digital asset custodians and exchanges, licensed payment platforms, payment services integrations, marketplace payments, content monetization, in-game currencies, asset-backed blockchain tokens, and non-fungible tokens.

Sarah provides actionable regulatory assessments that drive product development, marketing, and regulatory licensing strategies. She also drafts and negotiates commercial agreements, vendor contracts, and terms of service that support her clients' product launches. Clients appreciate that Sarah is well-versed in state and federal financial services regulations, particularly 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 to discuss the applicability of various financial services regulatory regimes to emerging blockchain technology platforms and protocols that her clients are developing.

Sarah provides guidance on 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 various international companies, Sarah has negotiated co-brand card deals, buy-now-pay-later payments integrations, and other significant payment processing arrangements. She also supports clients in financings, particularly on diligence questions related to digital assets, payments, and money services regulatory concerns.