January 26, 2022

Volume XII, Number 26


Stephen T. Middlebrook

Steve advises start-up and established companies on a wide array of legal and business issues arising from the intersection of technological innovation and financial services. He has over more than 20 years of experience helping clients navigate complex regulatory and compliance matters, including licensing, consumer protection, anti-money laundering, data privacy and security. He has helped clients interact with regulators and respond to inquiries at the state and federal level. In addition, he has assisted businesses in negotiating agreements for processing services, hardware and software, network access, and customer service.

Steve has an extensive background in emerging payment technologies, prepaid and stored value products, mobile payments, web-based financial services, virtual currency and distributed ledger technology. His prior experience includes being General Counsel at two FinTech companies, and a decade’s service at the US Department of the Treasury.

Steve serves as an advisor to the Uniform Law Commission’s drafting committee for the Regulation of Virtual Currency Businesses Act. He is a frequent writer on legal issues surrounding electronic payments and virtual currency with recent articles appearing in the Yale Journal of Regulation, William Mitchell Law Review and The Business Lawyer.


  • Led payments company that had suffered a significant processing outage through CFPB enforcement action, several state investigations, and multiple class action lawsuits.

  • Advised payment processor on modifying certain features of prepaid card program in order to be compliant with requirements of the Durbin Amendment.

  • Negotiated master services agreements with banking partner for payments company.

  • Advised payment processor on response to data breach.

  • Represented federal agency in patent litigation before the Federal Circuit.

  • Advised US Department of the Treasury on legal and compliance issues related to deployment of EagleCash, NavyCash and MarineCash stored value card products for the US Department of Defense.

  • Provided legal advice and counsel to US Department of the Treasury in support of the creation of the Direct Express prepaid debit card program through which millions of people receive their Social Security and other federal benefit payments.


Articles in the National Law Review database by Stephen T. Middlebrook