Steve Ganis

Of Counsel

vcard

(617) 348-1672 office phone

SGanis@mintz.com email

One Financial Center
Boston, MA 02111

Steve is Of Counsel in Mintz Levin’s Boston office, where he practices in the Litigation Section.

Steve has over a decade-and-a-half of experience as a government and private-sector lawyer practicing financial services law, specializing in the federal banking, securities, and derivatives laws. He is a globally recognized expert in the sub-specialties 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 U.S. 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 expertise 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 U.S. 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 the Financial Crimes Enforcement Network (FinCEN) concerning AML regulation and the prevention of money laundering and terrorist financing. In addition, Steve speaks and teaches frequently as an AML and OFAC expert, 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 Levin, Steve was the Chief Anti-Money Laundering and U.S. Sanctions Officer of 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 U.S. foreign policy and national security measures. He served as statutory AML officer for each of Fidelity’s U.S. mutual funds, broker-dealers, and banking entities, as well as a UK asset manager and a money services business. 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 LLP, 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 U.S. House of Representatives for five years during the late 1990s. 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 mafiya, 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.

Steve received his A.B., summa cum laude, from Dartmouth College and his J.D. from Harvard Law School. In between earning these two degrees, 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. Steve is admitted to practice in Massachusetts.

Admissions

Massachusetts

Education

Dartmouth College
AB
Harvard University
JD

Publications

What Concerns Do Mobile Devices Present for Hedge Fund Managers, and How Should Those Concerns Be Addressed? Part Three
What Concerns Do Mobile Devices Present for Hedge Fund Managers, and How Should Those Concerns Be Addressed? Part Two
What Concerns Do Mobile Devices Present for Hedge Fund Managers, and How Should Those Concerns Be Addressed? Part One
Using Finders to Assist in Financings: Understanding the Risks Associated with Unregistered Broker-Dealers
Positioning Compliance Programs to Defend Against Increased Enforcement When Financial Institution Account Holders Are Implicated in Fraudulent Schemes
Ignore the Cautions Identified by Third-Party Analysts at Your Own Risk
Using Finders to Assist in Financings Can Impose Significant Risks
Securities Alert: Using Finders to Assist in Financings Can Impose Significant Risks on Your Company
Desperately Seeking Dulmatin, Or Is It Abdul Martin Or Joko Pitono?
Foreign Corrupt Practices Act (FCPA) Alert: The DOJ’s FCPA Crackdown on the Pharmaceutical and Medical Devices Industry
BD Week Enforcement Alert (August 30, 2010)
Financial Services Advisory: House and Senate to Reconcile the Wall Street Reform and Consumer Protection Act
Enforcement Alert: Retain Even Your Contract Reps' Business-Related E-Mail - or Risk Fines
Start Planning Policies and Procedures to Comply with New Uptick Rule
Need AML Technology? Getting it Through Clearing Firms Can Be Cheaper
Securities Alert: New SEC Rule Regarding Short Selling — The “Alternative Uptick Rule”
Expect More Inquiries Soon; FinCEN Expanded Information Request Begins
AML Cases Emphasize the Need for Automation, Targeted Risk Assessment
Privacy and Security Alert: Supreme Court Upholds Requirement that the Government Prove Knowledge of Identity Theft
Ensuring Effective Broker-Dealer SAR Programs
Global Financial Crisis Alert: FBI Probes Role of 26 Firms in Financial Crisis
Global Financial Crisis Alert: Agencies Consider Reduction of Fannie Mae and Freddie Mac Debt Risk

Firm Directory

ML Financial Advisors LLC ML Strategies

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Steve is Of Counsel in Mintz Levin’s Boston office, where he practices in the Litigation Section.