Steve has over 15 years of experience as a government and private-sector lawyer practicing financial services law, specializing in the federal banking, securities, and derivatives laws. He is globally recognized for his knowledge of anti-money laundering (AML) and sanctions regulations.
He handles a wide range of matters for institutions and high-level financial services executives involving regulation of clearing and introducing broker-dealers, mutual funds, hedge funds, transfer agents, private equity funds, institutional investors, banks, thrifts, insurance companies, futures commission merchants, commodity trading advisors, commodity pool operators, foreign exchange and over-the-counter (OTC) derivatives dealers, money services businesses, clearing agencies, alternative trading systems, and futures and options exchanges.
Steve has represented firms as outside counsel, a compliance officer, or in-house counsel before all major US financial services regulators, including the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Agency (FINRA, formerly the NASD and NYSE), the Commodity Futures Trading Commission, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and various state banking regulators.
Steve has experience in the full range of laws governing regulated financial institutions, including the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940 (’40 Act), the Commodity Exchange Act, the Bank Holding Company Act, the Federal Reserve Act, the National Bank Act, the Federal Deposit Insurance Act, the Bank Secrecy Act of 1970 (including the USA Patriot Act), the International Emergency Economic Powers Act, the Trading with the Enemy Act, and the Foreign Corrupt Practices Act.
He analyzes and applies these statutes and their regulations to achieve practical business and operations solutions for a wide variety of sectors and activities, including asset management, transfer agency, retail and institutional brokerage, clearance and settlement, commercial banking, trust and custody services, payments processing, and spot, futures and OTC derivatives trading. In addition, Steve has considerable experience with due diligence and regulatory issues in mergers and acquisitions of financial services complexes.
From 2003 to 2008, Steve served on the US Department of the Treasury Bank Secrecy Act Advisory Group (BSAAG), a committee of regulators, law enforcement officials, and industry experts who advise the Director of FinCEN concerning AML regulation and the prevention of money laundering and terrorist financing.
Steve speaks and teaches frequently about AML and OFAC, including at the FINRA Institute at the Wharton School of Business and FINRA’s AML Boot Camp, and on numerous panels at conferences and seminars of the Securities Industry and Financial Markets Association (SIFMA, formerly SIA), the Investment Company Institute (ICI), the National Investment Company Service Association (NICSA), and other industry and bar associations.
Before joining Mintz, Steve was the chief anti-money laundering and US sanctions officer at Fidelity Investments, where for six years he centrally led programs throughout Fidelity to comply with the USA Patriot Act of 2001, the Bank Secrecy Act, various state and federal criminal money laundering statutes, OFAC sanctions, and other US foreign policy and national security measures. He served as statutory AML officer for each of Fidelity’s US mutual funds, broker-dealers, and banking entities as well as a UK asset manager and a money services business.
There, his responsibilities included overseeing all aspects of AML and OFAC compliance implementation and operation, including enterprise-wide compliance policy, strategy, and prioritization; response to suspicious customer activity; reporting to and governance by mutual fund and trust company boards; coordination with regulators, law enforcement, and industry regarding potential money laundering and terrorist financing; suspicious activity detection, name matching logic, and other requirements for transaction monitoring and customer due diligence systems and processes; development, maintenance, and enhancement of policies, procedures, and internal controls; integration of AML programs into Sarbanes-Oxley and ’40 Act Rule 38a-1 governance frameworks; and development and delivery of training content to approximately 20,000 employees every year.
Steve came to Fidelity from the law firm of Goodwin Procter, where he practiced banking, securities, and derivatives regulatory law, representing financial institutions on structure, new products, bank mergers and acquisitions, SEC enforcement, and banking litigation matters.
Steve was counsel to the Committee on Banking and Financial Services of the US House of Representatives for five years during the late 1990's. He advised the committee chairman and members on capital markets, securities, and government-sponsored enterprises. On Capitol Hill, Steve became full committee point person on swaps, derivatives, and proposed hedge fund legislation. In addition, he worked extensively for the committee on money laundering legislation and investigations of Colombian drug trafficking, hearings on the Russian mafia, and the restitution of laundered funds and assets to Holocaust victims and their families.
From 1992 to 1995, Steve served as a general attorney in the SEC Office of the General Counsel, where he advised the commission and divisions on legal issues arising in international, enforcement, market regulation, investment management, and legislative matters. Among other things, he worked at the SEC on cross-border disgorgement of laundered securities fraud proceeds.
After he received his bachelor’s degree, he won a Graduate Fellowship from Rotary International and pursued advanced studies in political science for a year at the Università degli Studi of Bologna, Italy. In college, he served as a White House intern.
Experience
- Developed intra-organization FCPA compliance delegation arrangements among affiliated asset management firms.
- Advise money services businesses on potential applicability and CFPB enforcement exposure.
- Spearheaded anti-corruption due diligence for US asset managers, overseeing privileged work by outside forensic/investigative services providers, in multiple significant potential investments by current and former senior foreign political figures and/or their relatives.
- Advise peer-to-peer and small business lending platform operators on nature and scope of prohibitions and CFPB enforcement exposure.
- Advised an asset management institution on identity theft “red flags” requirements under the Fair and Accurate Credit Transactions Act (FATCA).
- Advised credit card issuer regarding compliance with provisions of the Truth in Lending Act and Regulation Z, including with respect to ability to repay requirements (and related Fair Credit Reporting Act questions).
- Represented a financial services company in a FINRA investigation into the alleged improper storage of electronic records.
- Advised a lender on prohibition against conditioning credit extension on preauthorized automated clearinghouse (ACH) transfers.
- Investigated the entertainment of a South Korean sovereign wealth fund officials by a U.S. fund manager registered with the SEC as an investment adviser.
- Advised a large insurer on compliance and legal systems, processes, and risks regarding a contemplated initiative to accept premiums and/or pay claims in bitcoin.
- Developed anti-corruption programs for multiple biotech/cleantech companies, including pharmaceutical, medical device and diagnostics, including policies, procedures and controls for due diligence, agent oversight, expense monitoring, travel, meals and entertainment.
- Advised a large Fortune 500 company on legal and regulatory aspects of a significant transaction with a major bitcoin platform.
- Assist a large pharmacy chain in the implementation of TILA and Regulation Z compliance in their consumer charge account program.
- Advised a note holder and servicer on US sanctions restrictions applicable to loan extended US entity owned by “specially designated national” whose assets were blocked for arms trafficking.
- Advised US medical provider accreditation boards extensively on managing FCPA risks in structuring and negotiating transaction with consortium of national health regulators of several Middle East nations.
- Conducted internal investigation into Southeast Asian travel and entertainment of Algerian military officials for publicly traded US company that sells telecommunications equipment to Algerian military.
viewpoints
Energy & Sustainability Compliance with the Corporate Transparency Act — 2024
October 1, 2024 | Article | By David Adams, Steve Ganis
Read about your requirements under the CTA, which may include filing a Beneficial Ownership Information Report (BOIR) with the Financial Crimes Enforcement Network (FinCEN).
New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Clients
February 1, 2024 | Alert | By Will Perkins, Steve Ganis, Daniel Gaquin, Daniel Guggenheim, David Adams
Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA, many US entities will be required to provide the personal information of their beneficial owners to the Financial Crimes Enforcement Network (FinCEN), a division of the US Treasury Department.
RIA Succession Planning: Economic, Legal and Regulatory Considerations for Transitions and Exits
December 14, 2023 | Webinar
Compliance Dates Are Set: A Roadmap for Private Fund Advisers to Start Preparing for the SEC’s New Rules for Private Fund Advisers
October 4, 2023 | Alert | By David Adams, Kari Harris, Steve Ganis, Talia S. Primor
In this alert, we summarize the rules and provide a chart detailing key aspects of each rule and steps clients can take to prepare for implementation of the rules’ requirements.
Expansive SEC Predictive Data Proposal Surprises Broker-Dealers, Advisers & Technology Providers
August 10, 2023 | Alert | By David Adams, Steve Ganis, Kari Harris, Pete Michaels , Talia S. Primor
Read about recently proposed SEC rules for conflicts of interest in the use of predictive data analytics or similar technologies by broker-dealers and investment advisers.
SEC Moves Quickly On Its 55-Part Rulemaking Agenda
July 27, 2023 | Alert | By David Adams, Steve Ganis, Kari Harris, Pete Michaels , Talia S. Primor
Read about two new SEC rule proposals that would impact investment advisers and funds and SEC rulemakings in the works that would affect investment advisers or broker-dealers.
FINCEN Publishes Final Rule on Beneficial Ownership Requirements - A Critical Step Towards Heightened Transparency in U.S. Financial System
October 13, 2022 | Blog | By Steve Ganis, Kenneth Koch, Michael Goldberg, Jessica Zhang
On January 1, 2021, Congress passed the Corporate Transparency Act (“CTA” or the “Act”) to “better enable critical national security, intelligence and law enforcement efforts to counter money laundering, financing of terrorism, and other illicit activity.”
FinCEN Notice Launches Regulatory Process Requiring Covered Domestic and Foreign Companies to Report Beneficial Ownership to U.S. Government
April 5, 2021 | Blog | By Steve Ganis, William F. Weld, Taylor Shepherd
SEC Proposes Relief from Broker-Dealer Registration for Certain Finders
October 13, 2020 | Alert | By Steve Ganis
News & Press
The Best Lawyers in America 2025 Recognizes 184 Mintz Attorneys across 56 Practice Areas
August 15, 2024
187 Mintz attorneys have been recognized by Best Lawyers® in the 2025 edition of The Best Lawyers in America©. Notably, three Mintz attorneys received 2025 “Lawyer of the Year” awards, and 64 firm attorneys were included in the 2025 edition of Best Lawyers: Ones to Watch.
SEC’s Take on Predictive Data Analytics: A Failed Prediction?
September 25, 2023
David Adams and Steve Ganis were quoted in a FinOps Report article on the SEC’s take on the use of predictive data analytics by broker-dealers when determining conflicts of interest.
Mintz is pleased to announce that 120 firm attorneys have been recognized as leaders by Best Lawyers® in the 2024 edition of The Best Lawyers in America©.
Mintz Leads For Lido Advisors In Its Partnership With Colorado Financial Management
January 17, 2023
BOSTON – Mintz has served as legal counsel to wealth-management firm Lido Advisors LLC, a Charlesbank Capital Partners portfolio company, in its partnership with Colorado Financial Management (CFM).
Best Lawyers® recognized 108 firm attorneys in the 2023 edition of The Best Lawyers in America©. Notably, two Mintz attorneys – Poonam Patidar and Scott M. Stanton – received 2023 “Lawyer of the Year” awards, and 28 firm attorneys were included in the inaugural edition of Best Lawyers: Ones to Watch.
Global Cooperation Critical For Crypto Regulation
July 1, 2022
Mintz Advises JMP Group in Sale to Citizens Financial Group
November 16, 2021
Skill In Geopolitics Crucial For GCs Managing Sanctions
October 21, 2021
Mintz Member Steve Ganis Quoted On New Anti-Money Laundering Regulation in The New York Times’ DealBook Newsletter
April 13, 2021
Mintz Represents Right Networks in Sale of Controlling Interest to BV Investment Partners
October 11, 2016
Events & Speaking
Achieving Competitive Advantage Through Operational Excellence In Client Lifecycle Management
Online event
US Sanctions Relating to Russia
A Presentation to the Russian Union of Industrialists and Entrepreneurs
Moscow, Russia
3rd Summit on FCPA, AML and OFAC Risks for Private Equity & Hedge Funds
Park Lane Hotel, New York, NY
Increased Scrutiny by Regulators of Cybersecurity
The New England Broker/Dealer and Investment Adviser Association
Boston, MA
Life-Cycle of a Securities Sales Practice Dispute
Boston Bar Association
16 Beacon Street Boston, MA
Eight Things You Need To Know To Strengthen Your Sanctions Compliance Program
AML Services International
Webinar
ACFCS Financial Crime Conference & Exhibition
New York Hilton Midtown
1335 Avenue of the Americas New York, NY
Recognition & Awards
Best Lawyers in America: Banking and Finance Law (2023-2024)