Carl A. Fornaris: Lawyer with Greenberg Traurig, LLP

Carl A. Fornaris

Co-Chair, Financial Regulatory and Compliance Practice
Miami,  FL  U.S.A.

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Experience & CredentialsOther Offices

Practice Areas

  • Financial Regulatory and Compliance
  • Financial Institutions
  • Banking and Finance
  • Global
  • Corporate & Securities
Contact InfoTelephone: 305.579.0626
Fax: 305.961.5626
University University of Miami, B.S., 1990
Law SchoolThe Catholic University of America, Columbus School of Law, J.D., 1993
Admitted1993, Florida; 1995, District of Columbia; U.S. Court of Appeals for the District of Columbia Circuit; U.S. District Court for the District of Columbia
BornOctober 22, 1968

Carl A. Fornaris is Co-Chair of the firm's Financial Regulatory and Compliance Practice. With more than 20 years of legal experience, Carl concentrates his practice on the representation of financial services firms in all aspects of their business. In particular, he represents U.S. and non-U.S. firms on finance and corporate matters, and provides supervisory and compliance counseling for institutions regulated by the Federal Reserve, OCC, FDIC, FinCEN, CFPB, SEC, FINRA, Florida Office of Financial Regulation 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 letters of credit.

Carl advises banks, their holding companies, investment advisers, securities broker dealers, money services businesses and other financial institutions on capital-raising transactions, Volcker Rule implementation, CFPB compliance, critical examination reports and enforcement proceedings, and compliance with the Dodd-Frank Act, FATCA, USA PATRIOT Act/BSA/AML and OFAC sanctions programs. Carl also advises former officers and directors of failed banks in connection with threatened or actual administrative and civil claims.

Carl is the immediate 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.

Areas of Concentration

•Banking and financial services law, regulation and compliance
•Commercial lending
•Latin America cross-border transactions
•Anti-money laundering and OFAC compliance

Awards & Recognition

•Listed, South Florida Legal Guide, Top Lawyer, 2011-2015
•Listed, The Best Lawyers in America, Banking and Finance Law; Corporate Law; Financial Services Regulation Law; Securities / Capital Markets Law; Securities Regulation, 2008-2015
• Lawyer of the Year, Securities Regulation, Miami, 2014
•Listed, Chambers USA Guide, 2005-2015
•Listed, Super Lawyers magazine, Florida Super Lawyers, 2007-2015
•Team Member, Corporate/M&A - Law Firm of the Year, Chambers Latin America Awards, 2014
•Team Member, Corporate Board Member magazine and FTI Consulting Inc., one of America's Best Corporate Law Firms, 13th Annual Legal Industry Study, 2013
•Team Member, Corporate & Finance - Law Firm of the Year (Florida-Based), Chambers Latin America Awards, 2010, 2011 and 2013
•Member, team ranked as a top corporate law firm in Miami as selected by corporate directors, in the annual Legal Industry Research Study, Corporate Board Member magazine and FTI Consulting Inc. (10th year), 2002-2009, 2011-2012
•Listed, Chambers Global, 2009-2011
•Listed, Chambers Latin America, Corporate M&A, 2009
•Team Member, Focus on Latin America - Law Firm of the Year (Florida-Based), Chambers Latin America Inaugural Awards for Excellence, 2009
•Listed, Who's Who Legal Florida, 2008
•Listed, Florida Trend magazine, Legal Elite, 2006-2008
•Recipient, Pro Bono Service Award, Dade County Bar Association, 2005

Articles, Publications, & Lectures

•Quoted, Cuba's Open for Some American Business - So Here Come the Lawyers, Miami Herald, May 25, 2015
•Quoted, Florida Banks Cash in on New Tide of Miami Money, American Banker, May 15, 2015
•Quoted, Szubin Sets Out New Approach, eFinancial News, September 30, 2014
•Quoted, Florida Likely to Experience More M&A in 2014, American Banker, January 2, 2014
•Co-Author, USA PATRIOT Act--Final and Proposed Customer Due Diligence Regulations Applicable to Banks, Broker Dealers, Futures Commission Merchants and Mutual Funds, Electronic Banking Law and Commerce Report, March 2006

•Quoted, The Fundamentals of Hedge Fund Management, by Daniel A. Strachman, p. 48, 2007
•Update Author, Federal Bank Holding Company Law, 11th ed., 1995

•Moderator, Personal Liability Facing Financial Industry Compliance Professionals, 24th Annual Financial Markets Association Securities Compliance Seminar, Ft. Lauderdale, FL, April 24, 2015
•Speaker, Bank Executive Compensation, 9th Annual NACD Bank Director Workshop, American Association of Bank Directors, Ft. Lauderdale, FL, April 16, 2015
•Speaker, Customer Due Diligence and Beneficial Ownership, 15th Annual FIBA Anti-Money Laundering Compliance Conference, Miami, FL, March 6, 2015
•Moderator, De-Risking, 15th Annual FIBA Anti-Money Laundering Compliance Conference, Miami, FL, March 5, 2015
•Speaker, Virtual Currency/Bitcoin, Associate of Corporate Counsel Annual Meeting, New Orleans, LA, October 2014
•Speaker, Bitcoin: Legal and Regulatory Considerations, 14th Annual FIBA Anti-Money Laundering Compliance Conference, Miami, FL, February 20, 2014
•Moderator, FATCA panel, 13th Annual FIBA AML Compliance Conference, Miami, FL, February 14, 2013
•Speaker, Standard Chartered's Transaction Banking Workshop, Miami, FL, November 20-21, 2013
•Speaker, The Ongoing Offshore Impact of the US Dodd-Frank Act, Caribbean Regional Compliance Conference, St. Maarten, November 7, 2013
•Moderator, U.S. Supervisory Examination Updates, FIBA Risk Management Conference for the Americas, Miami, FL, October 4, 2012
•Speaker, FATCA Conference, Bogota, Colombia, May 24, 2012
•Panelist, FATCA panel, ASOCUPA (Panamanian Compliance Officers' Association), Panama City, Panama, March 26, 2012
•Moderator, FATCA panel, 12th Annual FIBA AML Compliance Conference, Miami, FL, February 23, 2012
•Moderator, FATCA panel, 11th Annual FIBA AML Compliance Conference, Miami, FL, February 24, 2011
•Panelist, FATCA Seminar, FEBRABAN - Federacao Brasileira de Bancos, Sao Paulo, Brazil, November 9, 2011
•Panelist, FATCA Compliance, Citibank Financial Institutions Forum, Miami, FL, June 10, 2011
•Moderator, Correspondent Banking Panel, 10th Annual FIBA AML Compliance Conference, Miami, FL, February 19, 2010
•Moderator, Bank CEO Panel, South Florida Banking Institute, Miami, FL, May 20, 2009
•Panelist, 7th Annual Offshore Alert Financial Due Diligence Conference, Miami Beach, FL, April 27, 2009
•Panelist, 9th Annual FIBA AML Compliance Conference, Miami, FL, February 19, 2009
•Moderator, Examination Issues from the Bank's Perspective, Institute for International Bankers' U.S. Regulatory and Compliance Orientation, New York, NY, July 17, 2008
•Panelist, New Legislative and Regulatory Initiatives, Financial Markets Association's 17th Annual Securities Compliance Seminar, Fort Lauderdale, FL, April 30, 2008
•Moderator, Anti-Money Laundering, FMA's Annual Securities Compliance Seminar, Fort Lauderdale, FL, April 30, 2008
•Panelist, Money Laundering in Brazil, Brazilian-American Chamber of Commerce of Florida, Miami, FL, April 18, 2008
•Panelist, M & A Update, National Association of Corporate Directors Bank Director Workshop, Fort Lauderdale, FL, April 8, 2008
•Moderator, A Regulatory Panel, South Florida Banking Institute, Miami, FL, May 23, 2007
•Panelist, The First Conference of the United States - Latin America Private Sector Dialogue on AML/CFT, Bogota, Colombia, April 2007
•Lecturer, Coping with Regulatory & Compliance Issues, National Association of Corporate Directors Bank Director Workshop, Fort Lauderdale, FL, March 29, 2007
•Lecturer, Financial Institution Business Continuity/Disaster Recovery: Legal And Compliance Primer, Terremark Worldwide, Inc. Conference, Miami, FL, November 2005
•Lecturer, The New U.S. Bank Secrecy Act Anti-Money Laundering Examination Manual: What You Need To Know Now, Offshore Alert Annual Due Diligence Conference, Miami, FL, November 2005
•Lecturer, The Law: Risk and Liability, Offshore Alert's 3rd Annual Financial Due Diligence Conference, Coral Gables, FL, October 2004
•Lecturer, New Threat of Russian Mob's Money Laundering, ACAMS, January 15, 2004
•Lecturer, Offshore Banking 3rd Annual Bear Stearns Central American/Caribbean Conference, Key Biscayne, FL, September 2003
•Lecturer, USA PATRIOT Act Update, International Bank Operations Association, Miami, FL, March 2003

•Quoted, Tale of the Texas Ratio: Two Banks that Failed, Daily Business Review, July 2010
•Guest Headnote, FDIC Poised To Sue Former Directors and Officers of Failed Banks, The Banking Law Journal at 97, February 2010
•Quoted, USA PATRIOT Act: SEC Brings First-Ever Enforcement Action Against Broker-Dealer for Noncompliance, Derivatives Financial Products Report, November 2006
•Quoted, Revised BSA Examiners Manual Less Vague, Adds Details on Risk, Insurance,, July 28, 2006
•Quoted, New Rules May Cost Banks Some Business, South Florida Business Journal, January 3, 2006
•Quoted, Feeling the Squeeze: Correspondent Banking, Latin Finance, May 2005
•Quoted, Bankers Are Learning To Live With PATRIOT Act Headaches, Miami Today, March 17, 2005
•Quoted, Foreign Bankers Rediscover South Florida, Miami Daily Business Review, February 15, 2005
•Quoted, Congressional Quarterly, March 2, 2004
•Quoted, Latin American Advisor, January 2004
•Interviewed, All Things Considered, National Public Radio, December 2003
•Quoted, Kiplinger's Personal Finance, September 2003
•Quoted, Treasury Proposes Tougher Money-Laundering Rules, Corporate Legal Times, July 2003
•Quoted, Banks Dig In Along the War's Front Line in a High Stakes Bid To Stop Money Laundering, Bank Technology News, March 2003
•Quoted, Latin America Advisor, November 25, 2002
•Quoted, The Very Long Arm of US Law, Latin Finance, June 2002
•Quoted, How Will New Financial Privacy Laws Impact Your Ancillary Services? Fee Income Growth Strategies, June 2000
•Quoted, Observations on Financial Modernization Law, Community Bank President, March 1, 2000

Associated News & Events

Press Releases

07.23.15 Greenberg Traurig Launches Financial Services Law Blog
06.11.15 95 Greenberg Traurig Attorneys Named 2015 Florida Super Lawyers and Rising Stars
06.11.15 48 Greenberg Traurig Miami Attorneys Named 2015 Florida Super Lawyers and Rising Stars
05.27.15 33 Greenberg Traurig Miami Shareholders Recognized in 2015 Chambers USA Guide
05.22.15 Greenberg Traurig Attorneys, Practices Included in the 2015 Chambers USA Guide
05.22.15 55 Greenberg Traurig Florida Attorneys Included in 2015 Chambers USA Guide
01.21.15 51 Greenberg Traurig Attorneys Recognized by South Florida Legal Guide
10.29.14 Greenberg Traurig's Lori Cohen, Arthur Don, Carl Fornaris and Alan Sutin Participate as Speakers at Association of Corporate Counsel 2014 Annual Meeting
09.25.14 Greenberg Traurig Named 'Corporate/M&A Law Firm of the Year - International Counsel in Latin America' at 2014 Chambers And Partners Latin America Awards for Excellence
08.19.14 128 Greenberg Traurig Florida Attorneys Listed In Best Lawyers In America 2015

Published Articles

02.01.10 FDIC Poised to Sue Former Directors and Officers of Failed Banks
10.18.02 Clean Fight


07.21.15 Little Known Florida Statute Affects Securities Issuers That Do Business in Cuba
07.13.15 FinCEN Issues Second South Florida GTO in Less Than Three Months
06.09.15 New York State Releases Final BitLicense Regulation
04.22.15 FinCEN Releases A Geographic Targeting Order Concerning Currency Reporting Laws in Certain Areas of Miami-Dade County
04.15.15 Recent DOJ and Regulatory Actions Against Smaller Institutions Suggest That Community Banks Should Continue to Carefully Consider BSA/AML Risks
01.30.15 AML Developments - FDIC Announces That It Will End Its Supervisory Trend of Expecting Regulated Institutions to 'De-Risk' Entire Categories of Customers
01.13.15 Coming Soon: New Background Check Obligations for Securities Broker-Dealers
09.09.14 Virtual Currency - New York State Extends Comment Deadline on BitLicense Proposal
08.25.14 USA PATRIOT Act/AML Update: FinCEN Issues Long-Awaited Proposed Regulations Regarding Beneficial Ownership Disclosure
09.12.13 'Skin in the Game' Credit Risk Retention Rules Re-Proposed (Also at Washington, D.C. Office)


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Little Known Florida Statute Affects Securities Issuers That Do Business in Cuba
Carl A. Fornaris,Yosbel A. Ibarra, July 29, 2015
While diplomatic relations between the United States and Cuba continue to normalize, issuers of securities sold in Florida should be mindful of a little-noticed but long-existing Florida statute that requires them to disclose any business activities in Cuba. Passed in 1992, Section 517.075 of the...

FinCEN Issues Second South Florida GTO in Less Than Three Months
Jared E. Dwyer,Carl A. Fornaris, July 14, 2015
Today, the Financial Crimes Enforcement Network (FinCEN), working in conjunction with U.S. Internal Revenue Service - Criminal Investigation (IRS-CI) and the United States Attorney’s Office for the Southern District of Florida, issued a Geographic Targeting Order (GTO) for Miami-Dade and...

New York State Releases Final BitLicense Regulation
Michael A. Berlin,Steven M. Felsenstein,Carl A. Fornaris,William B. Mack,Niall E. O'Hegarty, June 15, 2015
On June 3, 2015, the New York State Department of Financial Services (DFS) published its final BitLicense regulation. The regulation requires that firms engaged in “Virtual Currency Business Activity” that involves New York State or a New York resident apply to DFS for a BitLicense...

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Office Information

Carl A. Fornaris

333 SE 2nd Avenue, Suite 4400
MiamiFL 33131


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