Sr. Counsel, Digital Assets

At Early Warning, we’ve powered and protected the U.S. financial system for over thirty years with cutting-edge solutions like Zelle®, Paze℠, and so much more. As a trusted name in payments, we partner with thousands of institutions to increase access to financial services and protect transactions for hundreds of millions of consumers and small businesses.

Positions located in Scottsdale, San Francisco, Chicago, or New York follow a hybrid work model to allow for a more collaborative working environment.

Candidates responding to this posting must independently possess the eligibility to work in the United States, for any employer, at the date of hire. This position is ineligible for employment Visa sponsorship.

Overall Purpose

We are seeking an experienced Sr. Product Counsel to serve as a trusted advisor to help us shape the future of payments. As a member of our legal team, you will be the go-to subject matter expert responsible for advising the business on cutting edge, innovative and first-of-their-kind payment solutions at the center of the banking industry. You will partner with our Product, Compliance, Risk, Strategy, Marketing, Communications and our owner banks to solve a broad range of challenging and complex legal and regulatory issues across the product life cycle.

Essential Functions

• Serve as first-line legal counsel to the product team on all legal matters arising in the business unit

• Interpret and apply U.S. and international legal and regulatory frameworks and requirements applicable to payments, digital assets, blockchain, bank regulatory, and privacy including the GENIUS Act, the National Bank Act, Bank Secrecy Act (BSA), OFAC/sanctions compliance, EFTA/Reg E, UCC, UDAAP/UDAP, GLBA/Reg. P and evolving stablecoin and digital asset regulations.

• Guide business partners in the launch, experimentation, and scaling of innovative cross-border payment and digital asset solutions through commercially pragmatic, risk-calibrated legal guidance.

• Advise on evolving stablecoin and digital assets regulations.

• Support the Product and Contracts teams in the drafting and negotiation of commercial agreements.

• Partner closely with product, compliance, risk, and strategy teams to structure emerging payment, stablecoin, and blockchain solutions within evolving regulatory and network frameworks.

• Draft, review and approve clear and concise public facing disclosures, disclaimers, terms of use or other public facing documents pertinent to the products

• Assess legal and regulatory ambiguity and develop practical, innovation-enabling frameworks, policies, and guardrails for new products, corridors, settlement models, and payment rails.

• Advise clients both on individual customer contract issues and in designing contract language that supports business objectives.

• Advise on cross-border and international payment regulatory considerations, including digital assets, consumer disclosures, sanctions compliance, foreign exchange considerations, and settlement frameworks.

• Draft, review and negotiate a variety of complex commercial relationships supporting the business unit objectives, including strategic partner, sales and supplier agreements.

• Act as department expert on specialized product or legal issues in the context of contract negotiations, audits, litigation, regulatory exams and other legal proceedings.

• Assess legislative or regulatory developments with actual or potential impact on key product initiatives and strategies and partner with the business team to identify and implement related policies, standards, processes and practices.

• Liaison with other Legal and Compliance department personnel to provide seamless support to the business unit.

• Manage and supervise outside counsel as needed.

• May manage and supervise lower-level attorneys and/or other legal personnel.

• Assist with corporate governance functions.

• Support the company’s commitment to risk management and protecting the integrity and confidentiality of systems and data.

Minimum Qualifications

• Juris Doctor from an accredited law school; admission to Arizona or another State bar

• Eight or more years’ of in-house or corporate counsel experience, with strong background advising financial institutions or financial services companies on compliance with consumer financial services and privacy laws and regulations

• Ability to learn new substantive areas of the law

• Significant expertise and relevant experience advising financial services industry market participants regarding compliance with anti-money laundering, sanctions, data privacy, and consumer protection regulations including, for example, Bank Secrecy Act, FinCEN guidelines, FATF recommendations, OFAC sanctions, GLBA, CCPA, GDPR, Regulation E, CFPA/UDAAP, and FTC Act.

• Demonstrated experience advising on emerging or evolving regulatory frameworks in payments, cross-border money movement, digital assets, blockchain technology, or related financial infrastructure.

• Experience supporting innovative or first-to-market financial products or payment systems in fast-evolving and ambiguous regulatory environments.

• Strong business and product acumen, including the ability to balance innovation, regulatory risk, operational realities, and strategic business objectives.

• Demonstrated ability to make risk-based decisions and develop practical paths forward with imperfect or evolving regulatory guidance.

• Ability to understand and be responsive to the business’s needs and partner cross-functionally throughout the organization to achieve results while mitigating risk

• Strong presentation skills and excellent written and verbal communication skills

• Strong interpersonal and collaborative skills to build partnerships and alliances internally and with external partners at all levels of the organization

• Demonstrated experience identifying and resolving legal and regulatory issues quickly and effectively, with an ability to make real-time decisions with imperfect information

• Ability to comprehend and communicate complex law and regulation and judicial and regulatory interpretations of law and regulations to internal clients at all levels of the organization

• Organized with ability to prioritize multiple tasks and achieve objectives in a fast-paced environment

• Prior experience effectively managing outside legal resources.

• Unyielding commitment to highest professional ethics

• Ability to maintain professional licensing and memberships in appropriate professional organizations

• Background and drug screen

Preferred Qualifications

• Experience leading crypto/digital asset licensing or registration efforts (US and/or international), including regulatory strategy, planning, preparation and approval of charter and licensing applications, regulator engagement, and operational implementation.

• Expertise or working knowledge of international law applicable to payments

• Knowledge of/experience with foreign corridor digital asset and payments, privacy, anti-money laundering and economic sanctions regulations/frameworks.

• Experience working with and representing clients before foreign bank prudential and consumer protection regulators.

• Experience with stablecoin issuance, tokenized deposits, blockchain-enabled payment systems, wallet ecosystems, or crypto-native financial infrastructure

• Experience supporting cross-border payment products across multiple jurisdictions, corridors, or regulatory regimes

• Familiarity with evolving global regulatory frameworks and supervisory approaches related to digital assets and stablecoins

Physical Requirements

Working conditions consist of a normal office environment. Work is primarily sedentary and requires extensive use of a computer and involves sitting for periods of approximately four hours. Work may require occasional standing, walking, kneeling, and reaching. Must be able to lift 10 pounds occasionally and/or negligible amount of force frequently. Requires visual acuity and dexterity to view, prepare, and manipulate documents and office equipment including personal computers. Requires the ability to communicate with internal and/or external customers.

Employee must be able to perform essential functions and physical requirements of position with or without reasonable accommodation.

Candidates responding to this posting must independently possess the eligibility to work in the United States at the date of hire

The above job description is not intended to be an all-inclusive list of duties and standards of the position. Incumbents will follow instructions and perform other related duties as assigned by their supervisor.

The base pay scale for this position in:
Phoenix, AZ/ Chicago, IL / Washington, DC in USD per year is: $188,000 - $235,000.
New York, NY/ San Francisco, CA in USD per year is: $226,000 - $282,000.

Additionally, candidates are eligible for a discretionary incentive plan and benefits.

This pay scale is subject to change and is not necessarily reflective of actual compensation that may be earned, nor a promise of any specific pay for any specific candidate, which is always dependent on legitimate factors considered at the time of job offer. Early Warning Services takes into consideration a variety of factors when determining a competitive salary offer, including, but not limited to, the job scope, market rates and geographic location of a position, candidate’s education, experience, training, and specialized skills or certification(s) in relation to the job requirements and compared with internal equity (peers). The business actively supports and reviews wage equity to ensure that pay decisions are not based on gender, race, national origin, or any other protected classes.

Some of the Ways We Prioritize Your Health and Happiness

• Healthcare Coverage – Competitive medical (PPO/HDHP), dental, and vision plans as well as company contributions to your Health Savings Account (HSA) or pre-tax savings through flexible spending accounts (FSA) for commuting, health & dependent care expenses.

• 401(k) Retirement Plan – Featuring a 100% Company Safe Harbor Match on your first 6% deferral immediately upon eligibility.

• Paid Time Off – Flexible Time Off for Exempt (salaried) employees, as well as generous PTO for Non-Exempt (hourly) employees, plus 11 paid company holidays and a paid volunteer day.

• 12 weeks of Paid Parental Leave

• Maven Family Planning – provides support through your Parenting journey including egg freezing, fertility, adoption, surrogacy, pregnancy, postpartum, early pediatrics, and returning to work.

And SO much more! We continue to enhance our program, so be sure to check our Benefits page here for the latest. Our team can share more during the interview process!

Pursuant to the San Francisco Fair Chance Ordinance, we will consider for employment qualified applicants with arrest and conviction records.

Early Warning Services, LLC (“Early Warning”) considers for employment, hires, retains and promotes qualified candidates on the basis of ability, potential, and valid qualifications without regard to race, religious creed, religion, color, sex, sexual orientation, genetic information, gender, gender identity, gender expression, age, national origin, ancestry, citizenship, protected veteran or disability status or any factor prohibited by law, and as such affirms in policy and practice to support and promote equal employment opportunity and affirmative action, in accordance with all applicable federal, state, and municipal laws. The company also prohibits discrimination on other bases such as medical condition, marital status or any other factor that is irrelevant to the performance of our employees.