Sullivan
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Biography

Harvey practices primarily in the areas of international and domestic corporate finance and domestic corporate governance, investment management law, securities law, including the Investment Company Act and Investment Advisers Act, and corporation, limited liability company and partnership law. Harvey counsels domestic and foreign clients, and advises clients respecting domestic and offshore investments and transactions. He also counsels on CFIUS compliance in international transactions following enactment of FIRRMA and compliance requirements under the recently-enacted Corporate Transparency Act.

Harvey was formerly an associate professor of law at The University of Virginia School of Law (investment law, torts) and an adjunct professor at Boston College Law School (corporate finance). Harvey has advised and lectured in Israel, Ireland and Central and Eastern Europe. He has served as a board member of an NYSE-listed company and of an NASD company. Harvey has lectured in the United States and in China, England, the Czech Republic, Austria and Hungary on private-equity investment, institutional investment and public and private investment companies and other collective investment vehicles. As a member of the Advisory Committee, he counseled on the revised prudent investor rule, extensively analyzed and discussed in his treatises.

Education
  • University of Virginia School of Law (J.D., Order of the Coif)
    • (Executive Editor, Virginia Law Review)
  • Massachusetts Institute of Technology (B.S. (E.E.))
Bar & Court Admissions
  • Massachusetts
  • Virginia, 1971 (Associate Member)
  • U.S. District Court, Eastern District of Virginia
  • U.S. District Court, District of Massachusetts
  • U.S. Court of Appeals for the First Circuit
  • U.S. Court of Appeals for the Third Circuit
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. Court of Appeals for the Seventh Circuit
  • U.S. Court of Appeals for the Tenth Circuit
  • Supreme Court of the United States
Professional Qualifications
  • Military Service - Lieutenant, United States Navy, 1963-1967 (Naval Flight Officer, Fighter Squadron Eighty-Four)
  • Massachusetts, Virginia, and Boston Bar Associations
  • American Law Institute
  • Trustee and Treasurer, Albert Schweitzer Fellowship
  • Special Counsel, Division of Investment Management, Securities & Exchange Commission (1974)
  • BBA Drafting Committee, Ch. 156C Limited Liability Company Act
  • BBA Drafting Committee, BBA Comments on Opinion Accord
Awards & Honors
  • Recommended by The Legal 500 U.S. (2026)
  • Best Lawyers’ Boston Corporate Compliance Law Lawyer of the Year (2015, 2020)
  • Best Lawyers in America® (2007-2026)
  • Massachusetts Super Lawyers (2004-2005, 2007-2009, 2011-2012)
  • Who’s Who in America
Additional Publications
  • "Investment Management Law and Regulation," (Wolters Kluwer, 3rd ed., 2014; 2nd ed. 2004; 1st ed. 1978; Supp. 2022), with Professor Steve Thel
  • "Due Diligence as a Duty," as published in Inside the Minds: Business Due Diligence Strategies, Thomson Reuters (Nov. 2008)
Viewpoints
All Viewpoints
Cooking Up Pandemic Relief: the Restaurant Revitalization Fund and Grants to Food and Beverage Providers
In March 2021, the American Rescue Plan Act of 2021 (the “Act”) was signed into law. The Act provides for $1.9 trillion of relief to many individuals and businesses overcoming the economic impact caused by the COVID-19 pandemic. Among the Act’s intended recipients are food service providers and adult beverage producers, who may be eligible for grants under the newly established Restaurant Revitalization Fund (the “Fund”). The Small Business Administration (“SBA”) will administer the Fund and distribute up to $28.6 billion in grants to eligible restaurants and similar establishments, $5 billion of which is preliminarily earmarked for eligible businesses with gross receipts during 2019 of not more than $500,000. Which Businesses are Eligible? As you might guess from the name of the Fund, restaurants are of course eligible. Eligible to receive a grant in addition to conventional restaurants are food stands, food trucks and carts, caterers, bars and saloons, taverns, inns, lounges, brewpubs, tasting rooms, taprooms, licensed facilities or premises of a beverage alcohol producer where the public may taste, sample or purchase products, or other similar places of business in which the public or patrons assemble for the primary purpose of being served food or drink, including those located in an airport terminal or businesses that are tribally-owned. As a result, the Fund may prove critical for many businesses, including struggling craft breweries, distilleries and wineries. While many businesses are eligible for a grant from the Fund, businesses with more than twenty locations, public companies and government-operated providers are ineligible. In addition, some live venue operators who applied for certain grants under the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act are also ineligible. How much Money can a Business Receive from the Fund and How must it be Spent? A single-location business may receive a grant in an amount of up to $5 million. A business with two or more locations may receive a grant in an amount of up to $10 million. Generally, the amount a business will receive will be equal to the pandemic-related revenue loss of the business. In calculating the amount of the grant to a business, the SBA will generally compare a business’ 2019 and 2020 revenues. Funds may be used in a similar manner to those funds received for Paycheck Protection Program (“PPP”) loans. That is, funds from a grant must be spent on certain payroll costs, payments of principal or interest on mortgage obligations, rent payments, utilities, maintenance expenses, supplies, food and beverage expenses, covered supplier costs, operational expenses, paid sick leave and any other expenses the SBA determines to be essential to maintaining the business. It is also important to note that funds must be used by December 31, 2021 or may need to be returned to the U.S. Treasury. Can PPP Loan Recipients Receive Grants from the Fund? Yes, an otherwise eligible business may receive a Fund grant even if it previously received a loan under the PPP; the SBA will deduct any PPP loan amounts from such grant, however. It is important to note that the Fund’s distributions are grants. By contrast, previous relief programs, such as the PPP, generally provided loans (though potentially forgivable loans) to eligible businesses. How can a Business Apply for a Grant? The SBA will administer the Fund’s distribution. Unfortunately, as of the date of this advisory, the SBA’s application process is not yet open. Nonetheless, we expect the application to be available on the SBA’s website and, once available, that applications will be submitted directly through the SBA’s website (as opposed to being submitted through approved banks as is the case for the PPP). Similar to that for the PPP, however, applicants will need to make a good faith certification along with their application that the uncertainty of current economic conditions makes necessary the grant request to support the ongoing operations of the business. In addition, businesses owned and controlled by women and veterans and certain other socially and economically disadvantaged small businesses will receive priority for the first three weeks of the application period. Even if your business is not expected to receive priority, any eligible business should prepare to submit its application as soon as possible, as grants are otherwise made on a first-come first-served basis. Your business can prepare for the Act’s application process and keep up-to-date on other pandemic relief programs by consulting with your primary Sullivan attorney or reaching out to the authors of this advisory.
Identify and Report “Control” Investors: The Corporate Transparency Act of 2020
We write to advise you of important legislation just enacted in the United States and proposed legislation in the United Kingdom. The National Defense Authorization Act for Fiscal Year 2021 (NDAA) was recently passed by both houses of Congress and is in effect following a January 1, 2021 Congressional override of President Trump’s veto. The National Security and Investment Bill (NSIB), which has goals similar to CFIUS, is wending its way slowly and painfully through the legislative process in London. Turning to the domestic front first, buried within some 1,500 pages of the NDAA is the Anti-Money Laundering Act of 2020 (AMLA) and buried within the AMLA is the Corporate Transparency Act (CTA). The AMLA represents a giant overhaul of the country’s legislation on money laundering. Within that broad initiative, the CTA targets the use of shell companies not just to facilitate money laundering, but even to make investments in the United States by persons who are, or whose interests are considered to be, adverse to those of the United States. The CTA is the culmination of almost a decade-long effort by the Financial Crimes Enforcement Network (FinCEN) to crack down on shell companies. Cited as "the most significant anti-money laundering reform since 2001" by Congressman Emanuel Cleaver, the law provides federal oversight in an otherwise unregulated area. The CTA directs FinCEN to establish and maintain a national registry of beneficial ownership. This registry will not be available to the general public, although that information may be made available to federal agencies for national security, intelligence or law enforcement purposes, to law enforcement agencies upon court authorization, and, with customer consent (which likely will be demanded), to financial institutions to the extent necessary to fulfill their know-your-customer obligations. The CTA requires certain types of legal entities in the United States—stated in the act as "a corporation, limited liability company, or other similar entity"—to report their beneficial owners to FinCEN. However, there are many exceptions to the obligation to file reports, including exemptions for publicly held companies and many types of financial entities. The legislation is focused on small entities which are not otherwise required to report their ownership. A beneficial owner is defined as an individual who, directly or indirectly, "exercises substantial control over an entity or owns more than twenty-five percent of the entity." Pending clarifying regulations, contractual “control” may suffice. The report must be kept current and updated to reflect any change in substantial control ownership. Entities will need to report a beneficial owner’s name, address and date of birth and to provide a copy of driver’s license or other government identification. If an entity’s beneficial owner is another entity, as opposed to a natural person, it will have to report similar details about its ownership.  Accordingly, laddering entities will likely not avoid compliance. A number of questions have arisen during our preliminary review of the legislation, including the scope of various exceptions and reporting requirements. Implementing regulations, which may bring some clarity to these questions, are required to be finalized within one year. What is clear, however, is that the enactment of the CTA will necessitate process changes in many areas including transactional diligence and documentation, confidentiality undertakings, transfers of interest and ongoing compliance for entities required to report under the CTA. The firm has a task force, consisting of lawyers in our Boston, London and New York offices, responsible for advising clients on the CTA, the NSIB and its U.S. cousin, CFIUS, as well as other laws rules and regulations relating to potentially sensitive investments in, and disclosure of beneficial ownership of, United States and United Kingdom entities. As the CTA and the NSIB wend their way through their respective administrative and legislative processes, we will keep you apprised of developments. In the meantime, if you have any questions, please feel free to contact Harvey Bines (617-338-2828) or Truman Bidwell (212-660-3032) on U.S. matters and Mark Norris (+44 20 7448 1003) on U.K. matters.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
44 Sullivan & Worcester Lawyers Named as “Best Lawyers” Award Recipients
Boston MA – Sullivan & Worcester today announced that 44 lawyers were recognized in the 2026 edition of Best Lawyers in America®. Three Sullivan partners also earned the 2026 “Lawyer of the Year” recognition from The Best Lawyers in America®. 39 of the firm’s lawyers in Boston, New York and Washington, D.C. were named as “Best Lawyers in America®,” and five Sullivan lawyers were recognized as “Ones to Watch” in the U.S. Lawyers of the Year David Nagle, managing partner of Sullivan, Amy Sheridan, and Lewis Segall were selected as "Lawyer of the Year" in Boston for Litigation and Controversy – Tax, Employee Benefits (ERISA) Law, and Mergers and Acquisitions Law, respectively. Only one lawyer is recognized as a "Lawyer of the Year" in each practice area and geographic location. These individuals are notable for receiving significantly higher ratings in Best Lawyers’ rigorous assessment process among the thousands of leading lawyers peer-reviewed in their markets. Best Lawyers in America® The firm’s 2026 Best Lawyers in Boston include Victor Baltera (Real Estate Law); Howard Berkenblit (Corporate Governance Law, Corporate Law); Harvey Bines (Corporate Compliance Law, Corporate Governance Law); Ashley Brooks (Real Estate Law); Joel Carpenter (Tax Law); Henry Comstock Jr. (Trusts and Estates); Christopher Curtis (Tax Law); Patrick Dinardo (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation – Bankruptcy); John Graham (Nonprofit / Charities Law, Tax Law); Ira Gross (Commercial Litigation); David Guadagnoli (Employee Benefits (ERISA) Law, Tax Law); Warren Heilbronner (Real Estate Law); Zachary Hyde (Patent Law); Richard Jones (Tax Law); Karen Kepler (Real Estate Law), Caroline Kupiec (Tax Law); Thomas Meyers (Patent Law); Lisa Mingolla (Trusts and Estates); Louis Monti (Real Estate Law); Cornelius Murray III (Trusts and Estates); David Nagle (Litigation and Controversy – Tax, Tax Law); Nicholas O'Donnell (Commercial Litigation); Ameek Ashok Ponda (Tax Law); Gregory Sampson (Environmental Law, Land Use and Zoning Law, Real Estate Law); Lewis Segall (Mergers and Acquisitions Law); Amy Sheridan (Employee Benefits (ERISA) Law); Laura Steinberg (Commercial Litigation); Sarah Wellings (Tax Law) and Amy Zuccarello (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation – Bankruptcy). Sullivan’s 2026 Best Lawyers in Washington, D.C. include John Chilton (Mutual Funds); Cameron Cosby (Tax); Nicole Crum (Mutual Funds); David Leahy (Mutual Funds); David Mahaffey (Mutual Funds & Securities Regulation); and Stephanie Monaco (Corporate, Mutual Funds, Private Funds / Hedge Funds, & Securities Regulation). The firm’s 2026 honorees in New York include Carole Bass (Trusts and Estates); J. Truman Bidwell, Jr. (Corporate); Domenick Pugliese (Mutual Funds); and Constantine Ralli (Trusts and Estates). Best Lawyers: Ones to Watch Awardees Best Lawyers awards this recognition to attorneys who are earlier in their careers for their outstanding professional excellence in private practice in the United States. Sullivan’s five lawyers earning this award include Alexander Gansebom (Corporate Governance and Compliance Law, Corporate Law, Health Care Law, Mergers and Acquisitions Law, Real Estate Law); Emily Goldschmidt (Corporate Law); Ryan Rosenblatt (Commercial Litigation); Ashley Tan (Real Estate Law); and Eric Victorson (Securities / Capital Markets Law). Best Lawyers Selection Methodology Recognition by Best Lawyers in America® is based on a peer review process designed to capture the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical and legal practice areas. About Sullivan Sullivan & Worcester (Sullivan) is a global, mid-sized law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best‑in‑class client service.

Harvey E. Bines

Harvey practices primarily in the areas of international and domestic corporate finance and domestic corporate governance, investment management law, securities law, including the Investment Company Act and Investment Advisers Act, and corporation, limited liability company and partnership law. Harvey counsels domestic and foreign clients, and advises clients respecting domestic and offshore investments and transactions. He also counsels on CFIUS compliance in international transactions following enactment of FIRRMA and compliance requirements under the recently-enacted Corporate Transparency Act.

Harvey was formerly an associate professor of law at The University of Virginia School of Law (investment law, torts) and an adjunct professor at Boston College Law School (corporate finance). Harvey has advised and lectured in Israel, Ireland and Central and Eastern Europe. He has served as a board member of an NYSE-listed company and of an NASD company. Harvey has lectured in the United States and in China, England, the Czech Republic, Austria and Hungary on private-equity investment, institutional investment and public and private investment companies and other collective investment vehicles. As a member of the Advisory Committee, he counseled on the revised prudent investor rule, extensively analyzed and discussed in his treatises.

Viewpoints
All Viewpoints
Cooking Up Pandemic Relief: the Restaurant Revitalization Fund and Grants to Food and Beverage Providers
In March 2021, the American Rescue Plan Act of 2021 (the “Act”) was signed into law. The Act provides for $1.9 trillion of relief to many individuals and businesses overcoming the economic impact caused by the COVID-19 pandemic. Among the Act’s intended recipients are food service providers and adult beverage producers, who may be eligible for grants under the newly established Restaurant Revitalization Fund (the “Fund”). The Small Business Administration (“SBA”) will administer the Fund and distribute up to $28.6 billion in grants to eligible restaurants and similar establishments, $5 billion of which is preliminarily earmarked for eligible businesses with gross receipts during 2019 of not more than $500,000. Which Businesses are Eligible? As you might guess from the name of the Fund, restaurants are of course eligible. Eligible to receive a grant in addition to conventional restaurants are food stands, food trucks and carts, caterers, bars and saloons, taverns, inns, lounges, brewpubs, tasting rooms, taprooms, licensed facilities or premises of a beverage alcohol producer where the public may taste, sample or purchase products, or other similar places of business in which the public or patrons assemble for the primary purpose of being served food or drink, including those located in an airport terminal or businesses that are tribally-owned. As a result, the Fund may prove critical for many businesses, including struggling craft breweries, distilleries and wineries. While many businesses are eligible for a grant from the Fund, businesses with more than twenty locations, public companies and government-operated providers are ineligible. In addition, some live venue operators who applied for certain grants under the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act are also ineligible. How much Money can a Business Receive from the Fund and How must it be Spent? A single-location business may receive a grant in an amount of up to $5 million. A business with two or more locations may receive a grant in an amount of up to $10 million. Generally, the amount a business will receive will be equal to the pandemic-related revenue loss of the business. In calculating the amount of the grant to a business, the SBA will generally compare a business’ 2019 and 2020 revenues. Funds may be used in a similar manner to those funds received for Paycheck Protection Program (“PPP”) loans. That is, funds from a grant must be spent on certain payroll costs, payments of principal or interest on mortgage obligations, rent payments, utilities, maintenance expenses, supplies, food and beverage expenses, covered supplier costs, operational expenses, paid sick leave and any other expenses the SBA determines to be essential to maintaining the business. It is also important to note that funds must be used by December 31, 2021 or may need to be returned to the U.S. Treasury. Can PPP Loan Recipients Receive Grants from the Fund? Yes, an otherwise eligible business may receive a Fund grant even if it previously received a loan under the PPP; the SBA will deduct any PPP loan amounts from such grant, however. It is important to note that the Fund’s distributions are grants. By contrast, previous relief programs, such as the PPP, generally provided loans (though potentially forgivable loans) to eligible businesses. How can a Business Apply for a Grant? The SBA will administer the Fund’s distribution. Unfortunately, as of the date of this advisory, the SBA’s application process is not yet open. Nonetheless, we expect the application to be available on the SBA’s website and, once available, that applications will be submitted directly through the SBA’s website (as opposed to being submitted through approved banks as is the case for the PPP). Similar to that for the PPP, however, applicants will need to make a good faith certification along with their application that the uncertainty of current economic conditions makes necessary the grant request to support the ongoing operations of the business. In addition, businesses owned and controlled by women and veterans and certain other socially and economically disadvantaged small businesses will receive priority for the first three weeks of the application period. Even if your business is not expected to receive priority, any eligible business should prepare to submit its application as soon as possible, as grants are otherwise made on a first-come first-served basis. Your business can prepare for the Act’s application process and keep up-to-date on other pandemic relief programs by consulting with your primary Sullivan attorney or reaching out to the authors of this advisory.
Identify and Report “Control” Investors: The Corporate Transparency Act of 2020
We write to advise you of important legislation just enacted in the United States and proposed legislation in the United Kingdom. The National Defense Authorization Act for Fiscal Year 2021 (NDAA) was recently passed by both houses of Congress and is in effect following a January 1, 2021 Congressional override of President Trump’s veto. The National Security and Investment Bill (NSIB), which has goals similar to CFIUS, is wending its way slowly and painfully through the legislative process in London. Turning to the domestic front first, buried within some 1,500 pages of the NDAA is the Anti-Money Laundering Act of 2020 (AMLA) and buried within the AMLA is the Corporate Transparency Act (CTA). The AMLA represents a giant overhaul of the country’s legislation on money laundering. Within that broad initiative, the CTA targets the use of shell companies not just to facilitate money laundering, but even to make investments in the United States by persons who are, or whose interests are considered to be, adverse to those of the United States. The CTA is the culmination of almost a decade-long effort by the Financial Crimes Enforcement Network (FinCEN) to crack down on shell companies. Cited as "the most significant anti-money laundering reform since 2001" by Congressman Emanuel Cleaver, the law provides federal oversight in an otherwise unregulated area. The CTA directs FinCEN to establish and maintain a national registry of beneficial ownership. This registry will not be available to the general public, although that information may be made available to federal agencies for national security, intelligence or law enforcement purposes, to law enforcement agencies upon court authorization, and, with customer consent (which likely will be demanded), to financial institutions to the extent necessary to fulfill their know-your-customer obligations. The CTA requires certain types of legal entities in the United States—stated in the act as "a corporation, limited liability company, or other similar entity"—to report their beneficial owners to FinCEN. However, there are many exceptions to the obligation to file reports, including exemptions for publicly held companies and many types of financial entities. The legislation is focused on small entities which are not otherwise required to report their ownership. A beneficial owner is defined as an individual who, directly or indirectly, "exercises substantial control over an entity or owns more than twenty-five percent of the entity." Pending clarifying regulations, contractual “control” may suffice. The report must be kept current and updated to reflect any change in substantial control ownership. Entities will need to report a beneficial owner’s name, address and date of birth and to provide a copy of driver’s license or other government identification. If an entity’s beneficial owner is another entity, as opposed to a natural person, it will have to report similar details about its ownership.  Accordingly, laddering entities will likely not avoid compliance. A number of questions have arisen during our preliminary review of the legislation, including the scope of various exceptions and reporting requirements. Implementing regulations, which may bring some clarity to these questions, are required to be finalized within one year. What is clear, however, is that the enactment of the CTA will necessitate process changes in many areas including transactional diligence and documentation, confidentiality undertakings, transfers of interest and ongoing compliance for entities required to report under the CTA. The firm has a task force, consisting of lawyers in our Boston, London and New York offices, responsible for advising clients on the CTA, the NSIB and its U.S. cousin, CFIUS, as well as other laws rules and regulations relating to potentially sensitive investments in, and disclosure of beneficial ownership of, United States and United Kingdom entities. As the CTA and the NSIB wend their way through their respective administrative and legislative processes, we will keep you apprised of developments. In the meantime, if you have any questions, please feel free to contact Harvey Bines (617-338-2828) or Truman Bidwell (212-660-3032) on U.S. matters and Mark Norris (+44 20 7448 1003) on U.K. matters.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
44 Sullivan & Worcester Lawyers Named as “Best Lawyers” Award Recipients
Boston MA – Sullivan & Worcester today announced that 44 lawyers were recognized in the 2026 edition of Best Lawyers in America®. Three Sullivan partners also earned the 2026 “Lawyer of the Year” recognition from The Best Lawyers in America®. 39 of the firm’s lawyers in Boston, New York and Washington, D.C. were named as “Best Lawyers in America®,” and five Sullivan lawyers were recognized as “Ones to Watch” in the U.S. Lawyers of the Year David Nagle, managing partner of Sullivan, Amy Sheridan, and Lewis Segall were selected as "Lawyer of the Year" in Boston for Litigation and Controversy – Tax, Employee Benefits (ERISA) Law, and Mergers and Acquisitions Law, respectively. Only one lawyer is recognized as a "Lawyer of the Year" in each practice area and geographic location. These individuals are notable for receiving significantly higher ratings in Best Lawyers’ rigorous assessment process among the thousands of leading lawyers peer-reviewed in their markets. Best Lawyers in America® The firm’s 2026 Best Lawyers in Boston include Victor Baltera (Real Estate Law); Howard Berkenblit (Corporate Governance Law, Corporate Law); Harvey Bines (Corporate Compliance Law, Corporate Governance Law); Ashley Brooks (Real Estate Law); Joel Carpenter (Tax Law); Henry Comstock Jr. (Trusts and Estates); Christopher Curtis (Tax Law); Patrick Dinardo (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation – Bankruptcy); John Graham (Nonprofit / Charities Law, Tax Law); Ira Gross (Commercial Litigation); David Guadagnoli (Employee Benefits (ERISA) Law, Tax Law); Warren Heilbronner (Real Estate Law); Zachary Hyde (Patent Law); Richard Jones (Tax Law); Karen Kepler (Real Estate Law), Caroline Kupiec (Tax Law); Thomas Meyers (Patent Law); Lisa Mingolla (Trusts and Estates); Louis Monti (Real Estate Law); Cornelius Murray III (Trusts and Estates); David Nagle (Litigation and Controversy – Tax, Tax Law); Nicholas O'Donnell (Commercial Litigation); Ameek Ashok Ponda (Tax Law); Gregory Sampson (Environmental Law, Land Use and Zoning Law, Real Estate Law); Lewis Segall (Mergers and Acquisitions Law); Amy Sheridan (Employee Benefits (ERISA) Law); Laura Steinberg (Commercial Litigation); Sarah Wellings (Tax Law) and Amy Zuccarello (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation – Bankruptcy). Sullivan’s 2026 Best Lawyers in Washington, D.C. include John Chilton (Mutual Funds); Cameron Cosby (Tax); Nicole Crum (Mutual Funds); David Leahy (Mutual Funds); David Mahaffey (Mutual Funds & Securities Regulation); and Stephanie Monaco (Corporate, Mutual Funds, Private Funds / Hedge Funds, & Securities Regulation). The firm’s 2026 honorees in New York include Carole Bass (Trusts and Estates); J. Truman Bidwell, Jr. (Corporate); Domenick Pugliese (Mutual Funds); and Constantine Ralli (Trusts and Estates). Best Lawyers: Ones to Watch Awardees Best Lawyers awards this recognition to attorneys who are earlier in their careers for their outstanding professional excellence in private practice in the United States. Sullivan’s five lawyers earning this award include Alexander Gansebom (Corporate Governance and Compliance Law, Corporate Law, Health Care Law, Mergers and Acquisitions Law, Real Estate Law); Emily Goldschmidt (Corporate Law); Ryan Rosenblatt (Commercial Litigation); Ashley Tan (Real Estate Law); and Eric Victorson (Securities / Capital Markets Law). Best Lawyers Selection Methodology Recognition by Best Lawyers in America® is based on a peer review process designed to capture the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical and legal practice areas. About Sullivan Sullivan & Worcester (Sullivan) is a global, mid-sized law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best‑in‑class client service.