Sean Ruff

Core Areas of Focus

Licensing & Regulatory Strategy

• Nationwide money transmission licensing and compliance management
• State licensing for consumer and commercial lending, merchant cash advance, retail installment sales and compliance management
• Regulatory structuring for buy now, pay later, stored value, and embedded finance products
• Guidance on change-of-control processes and post-transaction license integration
• Advising on Bank Holding Company Act issues

Payments & Card Programs

• Structuring of prepaid, credit, and debit card programs, including co-branded and private-label arrangements
• Drafting and negotiation of bank sponsorship, processor, and program management agreements
• Compliance with ACH/NACHA rules, card network requirements, Reg E, and dispute resolution procedures
• Regulatory guidance on merchant acquiring, payment facilitation, payment processing, and digital wallet frameworks

Lending & Credit Products

• Development of consumer and commercial lending platforms, including marketplace, point-of-sale, and direct lending models
• Compliance with TILA, ECOA, FCRA, FDCPA, UDAAP, and related federal and state laws
• Structuring of commercial credit, corporate card, and merchant cash advance programs
• Counseling on non-bank lending partnerships, co-branded credit offerings, and program compliance

Digital Assets & Fintech Innovation

• Licensing and compliance
• Regulatory support for embedded crypto functionality, blockchain-based payments, and tokenization
• AML, sanctions, and consumer protection considerations
• Advising on evolving digital asset models

Transactional & Deal Support

• Financial regulatory due diligence for M&A, IPOs, and strategic investments involving fintech and financial institutions
• Risk assessments for financial services product portfolios and licensing requirements
• Drafting and negotiation of key financial services agreements, including:
  • Bank and sponsor relationships
  • Co-brand and issuing agreements
  • Processor, wallet, and vendor contracts

Compliance & Regulatory Engagement

• AML/BSA programs, including crypto-specific frameworks and FinCEN registration
• Internal compliance policies and controls for licensed financial institutions and fintech platforms
• Engagement with federal and state financial regulators
• Support for regulatory examinations, inquiries, and enforcement risk mitigation

Sean is a key member of Taft’s interdisciplinary Financial Services, FinTech and PayTech groups, collaborating with colleagues across corporate, M&A, privacy, litigation, and IP practices. Whether advising on product design, licensing strategy, or navigating regulatory change, Sean brings clarity and precision to important decisions involving financial innovation.

Recognized by Chambers FinTech: U.S. Payments & Lending, Sean is praised for his dual-industry perspective:

“What I love about him in particular is that he has worked on both sides—the industry side and the legal side. Since he has that experience, he is able to give really practical advice.”