Steve Ganis
- 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.
Case Study
Attorney Andrew Thorpe led a Mintz legal team that represented JMP Group LLC, a capital markets firm, in its sale to Citizens Financial Group.