Sullivan
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Biography

Chris is an experienced litigator who represents clients in federal and state court, as well as in arbitration.  He advises and represents clients in the financial services and technology industries in a wide range of disputes, including complex commercial, securities, banking, intellectual property, and shareholder matters.

Chris also has experience advising clients regarding regulatory matters and representing companies and individuals in connection with investigations and enforcement actions.  Prior to the joining the firm, Chris was a litigation associate at another international law firm in New York.

Education
  • Columbia Law School (J.D., Harlan Fiske Stone scholar)
  • Colgate University (B.A., magna cum laude)
Bar & Court Admissions
  • New York
  • U.S. District Court, Southern District of New York
  • U.S. District Court, Eastern District of New York
Awards & Honors
  • "Rising Star" New York Metro Super Lawyers (2026)
  • Recommended by The Legal 500 U.S. (2026)
Representative Matters
  • Obtained summary judgment and award of $3 million on behalf of creditor in breach of contract case
  • Successfully argued dismissal motion on behalf of leading technology company in federal suit concerning alleged interference with merger agreement (all claims dismissed)
  • Successfully challenged personal jurisdiction in federal suit for alleged breach of contract
  • Represented broker-dealer in connection with SEC investigation
  • Defended financial institutions in civil actions regarding alleged participation in fraudulent schemes and receipt of fraudulent transfers
  • Represented plaintiffs in pro bono civil rights action regarding discriminatory policing by sheriff’s department, resulting in entry of landmark consent decree
Viewpoints
All Viewpoints
FINRA’s Small-Cap Sweep: Strategic Steps for Broker-Dealers
It has been approximately one (1) month since the Financial Industry Regulatory Authority (FINRA) has launched a targeted review of broker-dealer activity in small-capitalization offerings involving foreign issuers—particularly those with operations in foreign jurisdictions such as China. The scope of the review extends across both public and private offerings of small-cap exchange-listed issuers and applies to firms that have acted as underwriters, bookrunners, syndicate or selling-group members, placement agents, or engaged in follow-on trading or omnibus account activity. For broker-dealers active in this market segment between January 1, 2023, and September 30, 2025, this initiative warrants immediate attention. FINRA’s focus underscores the need for firms to proactively strengthen compliance, supervisory and due-diligence frameworks before scrutiny is initiated. Implications for Broker-Dealers For broker-dealers that have acted in offerings of foreign-issuer small-cap companies, or engaged in corresponding trading, the risk of regulatory inquiry is now heightened. Firms should assume that FINRA may request detailed documentation of supervisory procedures, training materials, due-diligence records, compensation arrangements, and transaction lists. Potential exposure encompasses both the underwriting/placement side and the secondary trading side, particularly where omnibus accounts or affiliate-linked trading have occurred. Moreover, compliance weaknesses in this area may expose firms to broader regulatory focus given FINRA’s emphasis on market integrity and manipulative trading risks in small-cap IPOs. As a result, firms should view this not simply as a matter of historical transactions but as an active compliance priority for present-day operations and future offerings. Strategic Compliance Priorities and Action Plan Broker-dealers should undertake an immediate, firm-wide review of their involvement in relevant small-cap foreign-issuer offerings. This review should begin with an inventory of all transactions, public or private, in which the firm acted as underwriter, bookrunner, syndicate or selling-group member, placement agent, or participated in secondary trading during the relevant period. Firms should review whether their written supervisory procedures (WSPs), compliance manuals, training materials and internal guidance adequately address the risks particular to small-cap foreign-issuer offerings. This includes controls around due diligence of issuers, audit-firm and management backgrounds, beneficial-owner structures, cross-border legal/regulatory risks, syndicate compensation, and trading after the offering. Surveillance systems and trading desk controls should similarly be assessed to ensure they capture unusual trading patterns consistent with manipulative or coordinated activity. Firms should evaluate whether their AML/KYC programs are appropriately scaled to the enhanced risk of foreign issuers and thinly-traded securities, and whether their vendor-risk frameworks adequately cover third-party trading platforms, omnibus accounts, and algorithmic or remote trading tools. From a governance standpoint, senior management, compliance heads and the board should elevate this matter within their risk-assessment frameworks. Firms should consider whether internal audit scopes and independent reviews cover this business line, whether incentives or compensation structures may have encouraged participation in higher-risk offerings, and whether escalation procedures are clearly defined and monitored. Finally, firms should prepare for regulatory engagement by gathering and organizing deal files, training logs, supervisory review documentation, compensation records and transaction lists now, rather than waiting until a request arrives. Key Takeaways The targeted review by FINRA of small-cap foreign-issuer offerings signals a clear regulatory priority and a call to broker-dealers to raise their vigilance. For firms with exposure in this area, now is the time to act. Waiting until after a request is received may leave a firm scrambling and vulnerable to findings of deficient controls or documentation. The themes underpinning the review—cross-border risk, thin-traded securities, manipulative activity, and weak controls—are broader than the specific focus and should prompt firms to proactively enhance controls across the board. Senior leadership should not view this as a niche compliance issue, but rather as a signal of elevated scrutiny across multiple lines of business. With proper preparation, firms can not only respond to potential regulatory requests but demonstrate a thoughtful, forward-looking compliance program aligned with the evolving risk landscape.
Caught in a Revolving Door: The Supreme Court Determines Who Owes Honest Services
It is no secret that the modern U.S. Supreme Court has regarded enforcement of federal anti-corruption laws with a deep concern for constitutional overreach. That same concern animates petitioner’s arguments in Percoco v. United States, a case where the Court is examining the reach of federal anti-bribery laws and when an individual can be considered to be functioning as a public official. No. 21-1158 (U.S. argued Nov. 28, 2022). The Court’s holding could have profound effects on current and future lobbyists at all levels of government. The case was argued before the Court just over two weeks ago. If the questions posed to counsel are an indicator of future disposition, the Court seems amenable to overturning Mr. Percoco’s conviction. Following a trial in the United States District Court for the Southern District of New York, a jury convicted petitioner Joseph Percoco on two counts of conspiring to commit honest-services wire fraud in violation of 18 U.S.C. §§ 1346 and 1349 and one count of soliciting bribes or gratuities in violation of 18 U.S.C. § 666(a)(1)(B). The jury found that Percoco, who served as the Executive Deputy Secretary in the Executive Chamber to then New York Governor Andrew Cuomo, received $35,000 in bribes from Steven Aiello, a real estate developer, during an eight-month period in which Percoco had left that position to work for Governor Cuomo’s re-election campaign. Although Percoco was not employed by the state government at this time, he shared with others, including Aiello, his expectations of returning to his previous position under the Governor. In addition, he also “held onto and used his Executive Chamber telephone, desk, and office, where he continued to conduct state business.” Brief for Respondent, dated May 24, 2022, at 4. Near the end of Percoco’s time working for the Cuomo campaign, Aiello gave Percoco $35,000 for assistance in avoiding a “labor peace agreement” with local unions, a major obstacle to a development project.  Id.  Percoco then called the head of the state agency that had required the agreement be reached and implored the agency to reverse its decision and instead allow the development to move forward as is, leading the agency head to note the “pressure” he was receiving from his “principals.” Id. at 5. On the day after the call, the agency reversed its decision and permitted Aiello to proceed with his development without an agreement with local unions. Percoco rejoined the Governor’s Office four days later. The central issue before the Supreme Court concerns who may be liable for honest services fraud under 18 U.S.C. § 1346.  Percoco argues that his conduct -- a former government employee capitalizing on his clout and experience to aid a client interacting with the government -- is functionally identical to that of most lobbyists. See Brief for Petitioner, dated Feb. 17, 2022, at 1. Under this approach, lobbyists owe no fiduciary responsibility to the public writ large and, therefore, cannot fail to provide honest services under 18 U.S.C. § 1346. See id. In contrast, the United States counters that Percoco is unlike a traditional lobbyist because he left his government position “in name only,” continuing to “exercise a public office in fact” and was receiving money for influence after he “ha[d] been selected to return to the office.” Brief for Respondent at (I). The government contends that these distinctions placed Percoco within the ambit of 18 U.S.C. § 1346. The case has broad ramifications, likely affecting tens of thousands of state and local government officials and their staffs. A ruling upholding Percoco’s conviction may confound the abundantly common transition from government aide to and from campaign staff. The implications of such a potential holding were explored in the rigorous questioning about the government’s proposed rule to identify “government officials” for purposes of 18 U.S.C. § 1346 enforcement. Chief Justice Roberts and Justices Alito, Barrett, Gorsuch, Jackson and Kagan expressed varying degrees of concern regarding the workability or origin of the proposed rule, noting that such a broad application of 18 U.S.C. § 1346 would affect lobbyists and other people adjacent to government employees. If, despite these concerns, the Court were to adopt such a broad test, state and local government employees would do well to communicate clearly the start and end dates of their government employment (e.g., avoid using government office resources after their government tenure ends or before it starts when there is a pending nomination). The only member of the Court openly receptive to a broader definition of government official was Justice Sotomayor, who posited using principals of agency law to determine who owes the honest services to the public. SeeOral Argument at 57:02, Percoco(No. 21-1158), https://www.c-span.org/video/?524445-1/percoco-v-united-states-oral-argument. It appears quite possible that the Supreme Court will overturn Percoco’s conviction. If this were to happen, depending on the breadth of the Court’s reasoning, federal prosecutors might lament the hindrance of public corruption investigations by bribees obscuring exactly which hat they were wearing -- private citizen or public servant. Conversely, government employees and those lobbying them might be relieved to know that they will not be penalized for attempting to navigate the fluid career path between government and the private sector. The Court’s apparent inclination to vacate Percoco’s conviction and narrow the reach of federal anti-bribery laws would be consistent with the Roberts Court’s general wariness of the federal anti-corruption enforcement mechanism. This skepticism of such federal prosecution was reflected by Justice Thomas disapprovingly noting that this case illustrated the federal government “using a federal law to impose ethical standards on state activity.” Id. at 31:56.  From Skilling, in which honest services fraud was limited to instances of bribery and kickbacks (see Skilling v. United States, 561 U.S. 358, 408-09 (2010)), to McDonnell, which narrowed the definition of the “official action” that an alleged bribee must perform (see McDonnell v. United States, 579 U.S. 550, 576 (2016)), to Kelly, which rejected a broader conception of federal program fraud (see Kelly v. United States, 140 S. Ct. 1565, 1571 (2020)), and now seemingly Percoco, the U.S. Supreme Court has incrementally broadened the scope of permissible conduct that individuals may take to influence their government.
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.
Sullivan Attorneys Selected to 2026 New York Metro Super Lawyers and Rising Stars Lists
Super Lawyers has named 13 attorneys from Sullivan's New York office to its 2026 New York Metro Super Lawyers and Rising Stars lists. Attorneys are recognized for excellence in the practice of law, rated by a high degree of peer recognition and professional achievement. The recipients of this designation will be featured in New York Metro Super Lawyers magazine and The New York Times. The following Sullivan attorneys have been named 2026 New York Metro Super Lawyers: Carole Bass - Estate & Probate Keri Wintle Costello - Bankruptcy: Business Scott Kaufman - Mergers & Acquisitions Gerry Silver - General Litigation Michael Sullivan - Business Litigation Joel Telpner - Business/Corporate The following Sullivan attorneys have been named 2026 New York Metro Rising Stars: Joonas Aho - Securities & Corporate Finance Molly Depew - Estate & Probate Anna Lea (Setz) McNerney - Business Litigation Michael Palmisciano - Intellectual Property Christopher Shields - Business Litigation Zachary Sobel - Securities & Corporate Finance Ida Vanto - Mergers & Acquisitions