Shareholder / Co-Chair, Financial Regulatory & Compliance Practice
Carl A. Fornaris is Co-Chair of the firm’s Financial Regulatory and Compliance Practice. With 24 years of legal experience, Carl advises banks and their holding companies, investment advisers, securities broker dealers, money services businesses and other financial institutions on all aspects of their business, including licensing, capital-raising transactions, acquisitions and divestitures, USA PATRIOT Act/BSA/AML compliance and OFAC sanctions programs (including permissible financial activities in Cuba), critical examination reports and enforcement proceedings, Dodd-Frank Act compliance (including Volcker Rule implementation), new products and FATCA. Throughout his career, Carl has counseled clients in their dealings with the Federal Reserve, OCC, FDIC, FinCEN, SEC, FINRA, Florida Office of Financial Regulation, New York Department of Financial Services and other state supervisory authorities.
Carl is also active representing lenders and credit parties in financing transactions of all types, particularly credits to non-U.S. loan parties, asset-based credits, acquisition financing and stand-by letters of credit.
Carl is a past General Counsel of the Florida International Bankers’ Association and sits on the Board of Directors of FIBA. Previously, he served as Head of Legal and Compliance for the Latin America region of Barclays Bank PLC, with responsibility for managing legal and compliance matters throughout the region of Latin America. He began his legal career in Washington, D.C. with an international law firm. Carl is an adjunct professor in the Business Law Department of the University of Miami.
Overview of recent OFAC program related developments including discussion of sanctions programs such as Venezuela, Russia, Cuba, and Iran. Challenges for banks to navigate through the various OFAC sanctions and the direct and indirect sanctions risk stemming from sanctions evasion. Private industry issues.