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Greg D. Andres is a partner in Davis Polk’s Litigation Department and practices in the New York office. He concentrates in white collar criminal defense and represents clients in both civil and criminal trials. Greg previously served in senior government positions, including most recently as a Deputy Assistant Attorney General in the Criminal Division at the Department of Justice and the Chief of the Criminal Division at the U.S. Attorney’s Office in the Eastern District of New York.

The Anti-Money Laundering Act of 2020 implements the most extensive revisions to anti-money laundering law since the USA PATRIOT Act of 2001. The changes will affect both traditional financial institutions and FinTechs, including a new beneficial ownership provision that requires shell companies to submit ownership information to a non-public FinCEN
Continue Reading The Anti-Money Laundering Act of 2020 – Key Takeaways

On December 15, 2020, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking that would require substantially faster notification of cybersecurity incidents involving banking organizations, expand the list of triggering events, and impose first-of-its kind
Continue Reading Banking Agencies Propose Cyber Reporting Rule: Implications for Cybersecurity Compliance

The SBA has issued a long-awaited Procedural Notice providing guidance on the procedures for changes of ownership of an entity that has received Paycheck Protection Program funds.

Our memorandum contains flowcharts outlining when SBA consent is required for M&A transactions involving borrowers that want to sell their business to another
Continue Reading SBA Guidance: M&A Transactions and PPP Borrowers

We have published a memorandum on what companies and lenders need to know about oversight under the CARES Act and related enforcement risks. By reference to the global financial crisis, the memorandum provides a roadmap for companies and lenders thinking about and seeking to minimize the risks of participating in
Continue Reading Memorandum on CARES Act Oversight and Enforcement Risks for Companies and Lenders