Corporate · Fintech, payments, crypto

Fintech general counsel search for payments and crypto companies

The general counsel of a fintech owns the license, the partner bank, and the product release. The retained search is scored on that book.

Brief a search How we run a search

Lorenzo Sartori — Founder, Sartori & Partners Published September 30, 2026 — Fintech general counsel recruiter: 24-day shortlist on 38 GC/CLO searches since 2017; Series C fintech interim live on day 6

A fintech general counsel recruiter is the retained search for the lawyer who holds money-transmission licenses and bank-partner contracts. Of 38 General Counsel and Chief Legal Officer searches since 2017, the shortlist arrives in 24 days and the median accepted offer in 11 weeks (range 8-16). Regulation (EU) 2023/1114 set 1 July 2026 as the last MiCA transitional date for existing crypto-asset providers. A Series C fintech in San Francisco had interim counsel live on day 6, inside 60+ interim and fractional engagements. A NYSE-listed payments company in New York accepted a chief compliance officer in week 10.

01 Direct answer

A fintech general counsel recruiter is hired to find the lawyer who can hold a license and a partner bank.

The method is a retained general counsel search. The scorecard is licensing, money transmission, MiCA and PSD3, and the bank-partnership contract.

A fintech general counsel recruiter runs one retained search: the general counsel, or the first lawyer who will become one, at a payments company, a crypto company, or an embedded-finance company that is not itself the chartered bank. The work is the money-transmitter license, the FinCEN registration, the EU authorization under MiCA, the conduct rules coming through PSD3, and the contract with the partner bank that holds the balances. The cross-industry method, brief through offer, is a general counsel search. A chartered bank's officer is a bank general counsel search.

Sartori & Partners has completed 230+ in-house and corporate placements since 2017, of which 38 were General Counsel or Chief Legal Officer. The GC clock on those 38 is 24 days to shortlist and 11 weeks median to an accepted offer (range 8-16). Offer acceptance on corporate mandates is 96 percent. Retention of placed in-house leaders is 97 percent at 12 months and 91 percent at 24 months. The replacement term on a retained GC search is 12 months. Fintech and payments files sit inside those books. There is no separate fintech placement total.

Two files in this sector are published. A Series C fintech in San Francisco engaged an interim general counsel for parental leave plus a financing. Counsel was live on the work on day 6, inside 60+ interim and fractional engagements counted separately from the 230+. The median start on that interim book is 7 days. A NYSE-listed payments company in New York hired a chief compliance officer on a retained search: shortlist in week 3, accepted offer in week 10, one of 41 compliance and regulatory leadership placements. The market map behind the research program is 1,480,000+ lawyers (Sartori research program). A fintech slate is a named map of people who have held the license, not a published slice of that total.

Seat: General counsel for a payments, crypto or embedded-finance company. License, partner bank, product release.
Clock: Shortlist in 24 days; median accepted offer in 11 weeks; range 8-16 weeks (38 GC/CLO searches, 2017-2026).
Published files: Series C fintech, San Francisco: interim GC live on day 6 (of 60+ interim and fractional engagements). NYSE payments, New York: CCO shortlist week 3, offer week 10 (of 41).
Terms: Retained only. Fee 25-30 percent of total first-year compensation, 30 percent of the fee as retainer, 12-month replacement.
When interim: If the license date or a leave falls inside 11 weeks, interim cover starts on a 7-day median. The San Francisco file was live on day 6.
Research: Firm figures on this page are the track record published on the case studies, /about/ and /research/. External rules are cited in the sentence.

02 The rulebook on the scorecard

Four regimes. A generic GC specification misses all four.

Licensing, money transmission, MiCA and PSD3, and the partner-bank contract are the work the dossiers have to name.

Money transmission and MSB registration

FinCEN Form 107 within 180 days, renewed every two years, with no dollar threshold on money transmission. Cooley, 20 August 2024: every US state other than Montana has its own licensing statute. The GC has filed the applications and sat the exam.

MiCA, after 1 July 2026

Regulation (EU) 2023/1114 applied the crypto-asset service-provider regime from 30 December 2024. Article 143's last transitional date was 1 July 2026. A US money-transmitter résumé does not answer whether the firm is authorized for EU users.

III

PSD3 and the Payment Services Regulation

Proposed 28 June 2023. Provisional agreement 27 November 2025. ECON approval 5 May 2026. The 1 August 2026 legislative train still required formal adoption. The hire is scored on verification of payee, fraud-control liability, and strong customer authentication in a text that is agreed and not yet in force.

Bank partnerships

Joint guidance from the Federal Reserve, the FDIC and the OCC on 6 June 2023 (OCC Bulletin 2023-17) requires the bank to oversee the fintech for the life of the contract. The GC has negotiated the program agreement and can explain a ledger break.

Federal registration and state licensing are separate duties, and the general counsel is often the only officer who can see both. FinCEN's MSB rule, 31 CFR 1022.380, requires registration on Form 107 within 180 days after the business is established, and renewal every two years. Money transmission, unlike several other MSB categories, has no activity threshold: moving customer funds as a business is enough (FinCEN MSB registration page, citing 31 CFR 1010.100(ff) and 1022.380, in force in 2026). The same page records a criminal penalty of up to five years for a registration failure, under 18 USC 1960. State licensing sits beside that federal filing. Cooley reported on 20 August 2024 that every US state other than Montana regulates money transmission under a state-specific statute, and that state adoption of the CSBS Money Transmission Modernization Act had not produced one national rulebook. The lawyer who has "done payments" and has never opened an NMLS file is the wrong shortlist.

For a firm with EU users, MiCA is now an authorization question with a closed transitional window. Regulation (EU) 2023/1114 required authorization for crypto-asset service providers, with that regime applying from 30 December 2024. Article 143 allowed a Member State to let firms already providing those services under national law continue only until 1 July 2026, or until an authorization was granted or refused, whichever came first (ESMA newsletter, October 2023). The outer date has passed. The dossier asks where the firm stands: authorized, in a wind-down, or still describing EU users as reverse solicitation. A US licensing career does not, by itself, answer that question.

PSD3 is the next conduct rulebook, and it is not yet a law the company can be fined under. On 28 June 2023 the European Commission proposed a third Payment Services Directive and a Payment Services Regulation, COM(2023)366 and COM(2023)367. Parliament and the Council reached a provisional political agreement on 27 November 2025. The Parliament's economic and monetary affairs committee approved the agreed text on 5 May 2026. The Parliament's legislative train, in the edition updated 1 August 2026, still recorded that Parliament and Council had to adopt the deal formally before it could enter into force. Baker Tilly's note of 29 September 2026 still described formal adoption as expected in late 2026. The agreed text, as that train describes it, makes a payment service provider liable for customer losses where fraud-prevention controls failed, requires a check that the payee's name matches the account identifier, and keeps strong customer authentication. A general counsel hired in 2026 is scored on whether they can rebuild fraud controls and open-banking interfaces against that text.

The partner bank is the fourth file, and it is where fintech general counsel searches fail when the brief was copied from a software company. On 6 June 2023 the Federal Reserve, the FDIC and the OCC issued joint guidance on third-party relationships: OCC Bulletin 2023-17, Federal Reserve SR 23-4, and FDIC FIL-29-2023. The guidance covers the life cycle of the third-party arrangement, so oversight does not stop at signing. When balances at the program manager do not match the bank's ledger, end users lose access to funds and the general counsel owns the explanation to the board. We ask for the program agreement the candidate negotiated, the reconciliation break they lived, and who the customer of record was. Sector context for the hiring map is the fintech and payments industry page, the payments and money-transmission page, and crypto and digital assets, under financial services.

Stablecoin issuers have a US statute as well as a licensing theory. The Guiding and Establishing National Innovation for U.S. Stablecoins Act became Public Law 119-27 on 18 July 2025 (Congress.gov; Congressional Research Service IN12553, 20 August 2026). A GC at a firm that issues, holds, or settles a payment stablecoin is asked what they have done against that statute since July 2025.

03 Three seats, three clocks

The general counsel, the chief compliance officer, and interim cover are different briefs.

Full-time fintech GC

Standing legal work, a board that wants a named officer, a license or authorization with an owner, a partner bank that will ask who signs. Retained search on the GC clock: 24 days to shortlist, 11 weeks median to an accepted offer, range 8-16, across 38 GC and CLO searches since 2017. Fee 25-30 percent of total first-year compensation. Retainer 30 percent of the fee. Replacement term 12 months.

CCO beside the GC

At dual-regulated scale the legal bench is 15 to 40 lawyers plus a compliance function, and the compliance officer is not a deputy with a new title. The NYSE-listed payments company in New York hired a chief compliance officer against the DOJ Evaluation of Corporate Compliance Programs: shortlist in week 3, accepted offer in week 10, inside 41 compliance-leadership placements. The CCO clock is 21 days to shortlist and 10 weeks to offer. That search is chief compliance officer search. Sanctions and MLRO seats are sanctions and AML recruitment.

04 Who is actually in the pool

Sitting counsel in payments, crypto, and bank-partnership teams. A field we have published only as a band.

At Series B-C the median in-house bench is one lawyer. At dual-regulated scale it is 15 to 40 lawyers plus compliance. The person in the middle is the search.

Has held the license

Filed MSB registration, opened state money-transmitter applications, and sat an exam. Advice to a client who held the license is a different career. We mark the difference in the dossier.

Has been the bank's counterparty

Negotiated the program agreement, lived a reconciliation break, and can say who the customer of record is. The 6 June 2023 interagency guidance is the document the partner bank will cite.

Can still stop a launch

At Series B-C there is one lawyer. That lawyer still reads the customer contract and can halt a release when the license does not cover the flow. A department head who no longer drafts will staff a team the company cannot pay.

The maps we publish for these files are bands, not headcounts. For the San Francisco interim mandate we mapped sitting general counsel, recently departed general counsel, and known fractional counsel in Bay Area fintech and neighboring software who could start inside a week: a field in the tens. Availability was the scarce fact. For the New York payments chief compliance officer we mapped sitting chief compliance officers and heads of compliance at dual-regulated payments and fintech companies in New York: again a field in the tens. Conflicts on a financing, or on a partner bank already in the market, removed more names than competence did. We do not publish a finer cut, and the research program does not publish a fintech-only interview total. The market map is 1,480,000+ lawyers. The slate is the people who have done the work in the scorecard.

Three profiles come off the slate early. A listed-bank general counsel who has never owned a money-transmitter application is a bank search, and belongs on the bank general counsel brief. A product counsel who has cleared features and never sat with a supervisor cannot own the exam. A policy author, which is what an internal process produced before the New York payments committee retained a search, cannot name the last examination. At Series B-C the same person often holds licensing and the AML program until a chief compliance officer is justified. The team-size bands published with these files are the test: one lawyer at Series B-C; 15 to 40 lawyers plus a compliance function once the company is dual-regulated. The first-lawyer version of the build is a first general counsel search.

05 Mandate scorecard

Four lines we lock in week 1. Outreach does not start without them.

01
Reporting line. The general counsel reports to the chief executive. Where the company is dual-regulated, the chief compliance officer's line is written separately. On the NYSE payments file that line ran to the audit committee, with a working line to the general counsel. A compliance officer who can be overruled in a product meeting will not survive the examination.
02
The license or authorization that has a date. A money-transmitter exam, a MiCA authorization, a partner-bank diligence, a financing. If that date falls inside the 8-16 week GC range, interim cover is scoped in the same letter. The San Francisco file refused a permanent search against a leave date and was live on day 6.
03
Cash the board will pass. For a Series B-C first general counsel the published band is $240,000-$340,000 base and a 20-40% bonus. We do not open outreach on a number the compensation committee will not approve. Other stages are on the 2026 salary guide, read as stage bands, not as a fintech premium we have not published.
04
Off-limits, conflicts, and the fee. Fee, replacement window and off-limits are in the letter before anyone is called. We never recruit from a client's legal department for 24 months after a mandate. We never approach lawyers we placed for as long as they stay. A partner bank, a lead investor, and counsel to either are conflicts checked before a name reaches the CEO.

06 How the search runs

The GC clock is 24 days to shortlist. The median accepted offer is week 11.

Week 1 Mandate Blueprint
Reporting line, the license in flight, the partner-bank contract, cash, conflicts, off-limits. Written. No calls before this exists.
Weeks 1-2 Total-market mapping
Sitting GC and deputy GC in payments, crypto and bank-partnership teams. The published maps on these files were a field in the tens.
Weeks 2-4 Private outreach
Blind both ways until mutual interest. No CV leaves us without written candidate consent. NDA on request.
Day 24 Shortlist dossiers
Assessment dossiers. Each name has a license, an examination, or a bank-partner reconciliation the board can ask about.
Weeks 5-11 Interviews and offer
CEO, and the director who owns regulatory risk. Median accepted offer at week 11. Range 8-16 weeks across 38 GC/CLO searches.
After start Close and 90-day checks
Onboarding and 90-day check-ins. 97 percent of placed in-house leaders are still in post at 12 months; 91 percent at 24 months.

Process detail is how we run a search. The parent mandate is in-house and general counsel recruiting. The cross-industry GC brief is general counsel search. If the date will not wait 11 weeks, start at interim legal talent.

07 What to budget

The cash bands published on the fintech file. The fee is the retained GC fee.

Series B-C cash, interim day rates, and the fee below are the figures on the Series C fintech case and the corporate terms. They are not a new fintech compensation survey.

Cash and fee bands used on fintech and payments files. Sartori track record published on the case studies.
Item	Figure	Where it is published
Series B-C first GC base	$240,000-$340,000	Series C fintech case, San Francisco
Bonus on that base	20-40%	Same case
Interim GC day rate	$1,800-$3,200	Same case
Fractional GC, 2-3 days a week	$2,800-$4,500 a day	Same case
First-GC fractional, under $100 million revenue	$2,200-$3,400 a day	Same case
Retained fee	25-30 percent of total first-year compensation	Corporate terms, published on the case studies
Retainer	30 percent of the fee, at engagement	Corporate terms
Replacement	12 months on retained GC/CLO/CCO searches	Corporate terms

Days billed on interim or fractional cover credit against a later retained fee. Offer acceptance on corporate mandates is 96 percent.

Source: Sartori case studies: interim general counsel, Series C fintech, San Francisco; chief compliance officer, NYSE-listed payments, New York. Corporate terms as published on those files.

Stage bands beyond Series B-C, including listed-company totals, are on general counsel salary 2026. Company hub: legal hiring for companies. Firm background: founded in 2017.

08 Proof

38 GC and CLO searches. The fintech file is interim. The payments file is a chief compliance officer.

38: GC and CLO searches.Of 230+ in-house placements since 2017. No separate fintech total.; Sartori case studies
24 days: To a GC/CLO shortlist.Median accepted offer 11 weeks. Range 8-16.; Sartori case studies
Day 6: Series C fintech, San Francisco.Interim GC, inside 60+. Median start on that book is 7 days.; Sartori case study
Week 10: NYSE payments CCO, New York.Shortlist in week 3. One of 41 compliance-leadership placements.; Sartori case study

Published files

The two sector files. Timelines are the files, not a blended average.

Fintech · Series C · San Francisco

Interim general counselRead the case study

Situation: Parental leave landed on the same calendar as a financing. The company asked for a full-time general counsel. The bench at Series B-C is one lawyer.
Approach: Day-rate cover, conflicts cleared against the financing, a field in the tens who could start inside a week. Permanent search deferred.
Outcome: Live on the work on day 6. Counted in 60+ interim and fractional engagements, outside the 230+ permanent placements.

Timeline: Day 6 start. Program median is 7 days.

Payments · NYSE-listed · New York

Chief compliance officerRead the case study

Situation: The audit committee wanted a chief compliance officer who had sat across a supervisor. Dual-regulated companies run 15 to 40 lawyers plus a compliance function.
Approach: Dossiers written against the DOJ Evaluation of Corporate Compliance Programs. Reporting line to the audit committee.
Outcome: Shortlist in week 3. Accepted offer in week 10. One of 41 compliance and regulatory leadership placements since 2017.

Timeline: Week 3 shortlist. Week 10 accepted offer.

Client reference

What the buyer said

We thought we needed a full-time GC. They said fractional for two quarters, then a permanent search. Both were right. The fractional counsel started in a week.

Chief Executive Series C payments company · San Francisco

Offer acceptance on corporate mandates is 96 percent. Retention of placed in-house leaders is 97 percent at 12 months and 91 percent at 24 months. Those rates apply to permanent placements. The San Francisco file is interim cover, so the retention rates are not a claim about that day-rate engagement. The 12-month replacement term applies to retained GC, CLO and CCO searches.

09 Related

Read beside this search.

General counsel search

The retained GC and CLO method this sector brief sits inside: brief, map, slate, offer.

GC search

Fintech and payments

The industry hub: licensing, bank partnerships, and the legal seats payments companies hire.

Industry hub

Payments and money transmission

State licensing, BSA/AML, and the partner-bank stack for payments companies.

Payments industry

Crypto and digital assets

Securities, commodities, money transmission, and the GC seat at a crypto company.

Crypto industry

Bank general counsel

The chartered bank and broker-dealer seat: examiner relations, Dodd-Frank, Basel.

Bank GC search

Chief compliance officer

The NYSE payments file: audit-committee line, ECCP, shortlist in week 3, offer in week 10.

CCO search

Interim general counsel

Day-rate cover when the license date or a leave will not wait 11 weeks.

Interim GC

Series C fintech, San Francisco

The published interim file: live on day 6, then a permanent search on an honest calendar.

Read the case

For companies

In-house, compliance, legal operations and interim under one corporate desk.

Company hub

Fintech general counsel search — questions

What does a fintech general counsel recruiter search for?

A lawyer who already owns money-transmission licenses, a bank-partner contract, or an EU crypto authorization, and who can still sit with the CEO. Of 38 General Counsel and Chief Legal Officer searches since 2017, the shortlist arrives in 24 days and the median accepted offer in 11 weeks (range 8-16). The published fintech file is an interim general counsel for a Series C company in San Francisco, live on day 6, inside 60+ interim engagements counted apart from 230+ permanent placements. The published payments file is a chief compliance officer for a NYSE-listed company in New York: shortlist in week 3, accepted offer in week 10. The cross-industry method is a general counsel search.

How is this different from a general counsel search?

The clock and the fee are the same retained GC search. The scorecard is the sector. A general counsel search hires the company's chief legal officer across industries. This brief tests licensing, money transmission, MiCA and PSD3, and the partner bank. A chartered bank, with examiner relations under Dodd-Frank and Basel, is a bank general counsel search. The industry maps are fintech and payments, payments and money transmission, and crypto and digital assets.

What licensing work should a fintech general counsel already have done?

Federal MSB registration and the state money-transmitter book. FinCEN requires Form 107 within 180 days of the business being established, renewed every two years, and money transmission has no dollar threshold before that duty attaches (FinCEN MSB registration page, 31 CFR 1022.380 and 31 CFR 1010.100(ff), in force in 2026). Failing to register can bring a criminal penalty of up to five years under 18 USC 1960. Cooley reported on 20 August 2024 that every US state other than Montana regulates money transmission under its own statute. We ask who filed, who posted the surety, and who sat the exam.

What should the scorecard test on MiCA and PSD3 in 2026?

MiCA, Regulation (EU) 2023/1114, applied the crypto-asset service-provider regime from 30 December 2024. Article 143 set 1 July 2026 as the last date a Member State could let an existing provider continue without authorization (ESMA newsletter, October 2023). That outer date has passed. PSD3 and the Payment Services Regulation were proposed on 28 June 2023. Parliament and Council reached a provisional agreement on 27 November 2025. The Parliament's ECON committee approved that text on 5 May 2026. The legislative train's edition of 1 August 2026 still required formal adoption before entry into force, and Baker Tilly's note of 29 September 2026 still treated adoption as a late-2026 event. The hire is scored on a politically agreed text, not on a law already in the Official Journal.

How long does a fintech general counsel search take?

On the 38 GC and CLO searches since 2017, the shortlist arrived in 24 days and the median accepted offer in 11 weeks. The range is 8-16 weeks. A Series C fintech in San Francisco did not have 11 weeks: parental leave and a financing overlapped, and interim counsel was live on day 6. Across 60+ interim and fractional engagements the median from first call to start is 7 days. That book is separate from the 230+ permanent placements. See how we run a search and the San Francisco interim file.

What should we budget for a fintech general counsel?

The band published against the Series C fintech file, for a Series B-C first general counsel, is $240,000-$340,000 base plus a 20-40% bonus. Interim GC cover on that file is a day rate of $1,800-$3,200. Fractional GC at two to three days a week is $2,800-$4,500 a day. First-GC fractional below $100 million of revenue is $2,200-$3,400 a day. The retained fee is 25-30 percent of total first-year compensation, with 30 percent of the fee paid at engagement. Days billed on interim cover credit against a later retained fee. Wider stages sit on the general counsel salary guide for 2026.

Do you run fintech GC searches on retained terms only, and where?

Yes. GC, CLO and CCO searches are retained. The fee is 25-30 percent of total first-year compensation. A retainer of 30 percent of the fee is paid at engagement. The replacement window is 12 months. We never approach lawyers we placed for as long as they stay, and we do not recruit from a client's legal department for 24 months after a mandate. The firm was founded in 2017 by Lorenzo Sartori, with US hubs in New York, California and Texas and a network in Brussels, Dubai and Riyadh (about the firm). The two published files in this sector are San Francisco and New York.

Sources

External sources cited on this page.

Sources

11 references

FinCEN — Money Services Business registration (31 CFR 1022.380) fincen.gov ↗
Cooley — US states and the Money Transmission Modernization Act, 20 August 2024 cooley.com ↗
Regulation (EU) 2023/1114 — Markets in Crypto-assets (MiCA) eur-lex.europa.eu ↗
ESMA newsletter, October 2023 — MiCA transitional period through 1 July 2026 esma.europa.eu ↗
European Parliament legislative train — Payment services regulation, edition of 1 August 2026 europarl.europa.eu ↗
European Commission — PSD3 proposal, COM(2023)366, 28 June 2023 eur-lex.europa.eu ↗
Baker Tilly — PSD3 and PSR, 29 September 2026 bakertilly.de ↗
Congress.gov — GENIUS Act, Public Law 119-27, 18 July 2025 congress.gov ↗
Congressional Research Service — IN12553, 20 August 2026 congress.gov ↗
OCC Bulletin 2023-17 — Third-party relationships, 6 June 2023 occ.gov ↗
Sartori research program sartoriglobal.com ↗

Fintech general counsel

Brief the search against the license and the partner bank.

Retained. Fee, replacement window and off-limits in the letter before we call anyone. No obligation.

Brief a search How we run a search

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