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.
