Maria Vullo

Implemented supervisory priorities and enforcement actions at NYDFS that concretely shaped operational requirements for trust companies issuing tokenised assets. Actions under this tenure included specifying expectations for independent attestations, custody segregation, insurance coverage and AML controls for firms operating under a trust charter. Paxos’ operational model for PAXG took shape against these regulatory expectations, leading to documented monthly attestations and custody practices. Worked with regulated entities through examinations and guidance clarifying reporting frequency and content for reserves backing customer‑facing products. The enforcement posture encouraged issuers to formalise custodian contracts, insurer arrangements and audit access procedures that underpin public claims about one‑to‑one backing — practices that Paxos implemented for PAXG reserves and public attestations. Engaged in stakeholder communications that reduced ambiguity on acceptable operational controls for tokenised asset issuance under New York supervision. The resulting compliance checklist and examination focus areas were directly reflected in how PAXG’s reserve reporting, external attestations and custody segregation were structured and disclosed to market participants.