Natasha J. Dempsey
Senior Counsel
Overview
Natasha Dempsey is a financial services attorney in Holland & Knight's Denver and Washington, D.C., offices. Ms. Dempsey advises banks, credit unions, non-depository financial institutions and financial technology (FinTech) companies on regulatory compliance, supervisory and enforcement matters, digital assets, payments and environmental, social and governance (ESG) issues.
Ms. Dempsey helps clients assess risk, respond to regulatory change and make practical business decisions in a highly regulated financial services market. Her practice includes counseling financial institutions, corporations and emerging businesses on regulatory, corporate and transactional matters before major federal and state financial regulatory agencies. She also advises on bank regulatory compliance, complex transactions, climate-related financial risk and other ESG considerations.
Ms. Dempsey's financial services regulatory work spans lending and credit, payments, Bank Secrecy Act/anti-money laundering (BSA/AML) compliance, subscription and automatic renewal programs, prepaid and gift cards, credit reporting, unfair and deceptive trade practices, financial privacy and consumer data. She also advises on retail banking products and core supervisory requirements under state and federal law, including the Bank Holding Company Act, National Bank Act, Federal Deposit Insurance Act and Dodd-Frank Wall Street Reform and Consumer Protection Act.
She works with companies operating at the intersection of FinTech and digital assets, including money services businesses (MSBs), on BSA/AML compliance, Financial Crimes Enforcement Network (FinCEN) requirements, state licensing and emerging federal frameworks, including requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.
In her ESG practice, Ms. Dempsey advises on climate-related financial risk, corporate social responsibility initiatives and governance frameworks designed to align with state and global standards.
Prior to joining Holland & Knight, Ms. Dempsey was an attorney at a global law firm, where she advised financial institutions, FinTech companies and other businesses on a broad range of banking, payments, digital asset, compliance and ESG matters. She also held an in-house role at a major financial institution, giving her firsthand perspective on the regulatory, compliance and business challenges her clients face.
Representative Experience
- Advised national banks and federal savings associations on U.S. Department of the Treasury Office of the Comptroller of the Currency (OCC) Heightened Standards, safety and soundness requirements, and supervisory expectations, including preparation of formal responses to examination findings and board-level reporting
- Counseled state-chartered and federally chartered depository institutions on permissible activities, fiduciary and custodial activities, brokered deposit requirements and regulatory compliance under state and federal banking law
- Advised banks on Regulation E (electronic fund transfers), Regulation CC (funds availability), fair lending requirements and Community Reinvestment Act (CRA) compliance, including risk assessments, program design and examination preparation
- Counseled financial institutions on model risk management frameworks and third-party risk management programs, including vendor due diligence, ongoing monitoring and alignment with interagency guidance
- Advised credit unions and credit union service organizations on permissible activities and share insurance coverage requirements
- Advised a large financial market utility on bank clearing requirements, permissible activities for state-chartered and federally chartered depository institutions, and bank capital requirements
- Represented both banks and financial technology (FinTech) companies in structuring and negotiating bank-FinTech partnership agreements across lending, payments and co-branded card programs
- Advised a FinTech company on the regulatory framework for co-branded card programs, including card network compliance and issuing bank requirements
- Drafted consumer-facing disclosures and compliance policies addressing Truth in Lending Act (TILA), Equal Credit Opportunity Act, Fair Credit Reporting Act (FCRA) and unfair, deceptive, or abusive acts or practices for multiple clients, including digital lending platforms, payment providers and consumer financial services companies
- Advised lenders, servicers and money transmitters on 50-state licensing requirements, including product design, program and policy development, and preparation of license applications
- Advised new and used car dealers on in-house financing and indirect auto lending requirements under federal and state consumer lending laws
- Advised on consumer protections and residential subscriber requirements for solar programs, including disclosure obligations and financing compliance
- Represented a financial technology (FinTech) lender in a multistate enforcement investigation, drafting responses and negotiating a remediation plan with state financial regulators
- Represented multiple money services businesses and money transmitter licensees in state enforcement actions, including preparation of formal responses and negotiation of remediation plans
- Counseled healthcare, manufacturing, retail and technology companies on payments compliance, including regulatory requirements applicable to payment processing, merchant services and consumer-facing payment products
- Advised payment providers on product and program design for Nacha compliance, including origination requirements, return handling and risk management obligations
- Counseled clients on product and program design for Payment Card Industry Data Security Standard (PCI DSS) compliance and card network rules, including data security requirements and issuer and acquirer obligations
- Advised multiple clients on gift card and prepaid program regulatory analysis, product and program design, and consumer-facing disclosures under federal and state law
- Advised a money services business on Bank Secrecy Act/anti-money laundering (BSA/AML) and Know Your Customer/Costumer Identification Program compliance in connection with its state licensing applications and ongoing regulatory obligations
- Led regulatory due diligence on a complex acquisition involving a payments company, identifying licensing gaps and drafting remediation recommendations
- Supported due diligence and transactional work for bank tax equity financing transactions involving banks regulated by the U.S. Department of the Treasury's Office of the Comptroller of the Currency
- Advised a regional bank on climate-related financial risk disclosures and helped develop an internal governance framework aligned with emerging supervisory expectations
- Provided advice and drafting support for California climate-related disclosure obligations, including assessment of reporting requirements and preparation of compliance materials
- Drafted comprehensive ESG policies, global codes of conduct and human rights statements for U.S.-based clients serving United Kingdom and European Union companies, aligning governance frameworks with international standards
- Counseled a financial institution on the design and implementation of a corporate social responsibility initiative, including fair lending requirements and components related to the Community Reinvestment Act (CRA)
- Conducted an ESG-focused risk assessment for a publicly traded company, identifying control gaps and recommending policy updates to strengthen compliance readiness
- Advised a financial technology (FinTech) company on the regulatory classification of its stablecoin product under federal and state money transmission laws, including Financial Crimes Enforcement Network (FinCEN) registration and state licensing requirements
- Provided guidance on stablecoin issuance, reserve requirements and custody arrangements under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act and impending federal regulations
- Advised digital asset providers on FinCEN requirements and state money transmitter licensing obligations, including regulatory considerations for hosted wallets and fiat currency conversion
- Counseled a digital asset exchange on Bank Secrecy Act/anti-money laundering (BSA/AML) compliance obligations, developing its transaction monitoring framework and suspicious activity reporting protocols
Credentials
- Baylor Law School, J.D.
- Baylor University, Hankamer School of Business, MBA
- University of Colorado at Colorado Springs, M.A.
- The University of Texas at Arlington, B.A.
- Colorado
- District of Columbia
- Texas
- American Bar Association (ABA), Business Law Section
- Corporate Sustainability Law Committee, Co-Chair, 2025-2028
- Banking Law Committee, Payments and Electronic Banking Subcommittee, Vice Chair, 2023-2027
- Corporate Sustainability Law Committee, Banking Law Liaison, 2024-Present
- Banking Law Committee, Pro Bono Subcommittee, Chair, 2023-Present
- Consumer Financial Services Law Committee, Member, 2017-Present