Luigi L. De Ghenghi
  1. Partner

Mr. De Ghenghi is a partner in Davis Polk’s Financial Institutions Group. His practice focuses on bank M&A, strategic bank regulatory and financial reform advice, and capital markets transactions for U.S. and non-U.S. banks and other financial institutions. He is experienced in advising on Basel III regulatory capital and liquidity issues, living wills, enhanced prudential standards and a wide variety of financial regulatory matters.

He is also experienced in advising banks and other financial institutions on corporate governance and compliance matters, bank insolvency issues, government investigations and enforcement actions, cross-border collateral transactions, and clearance and settlement systems.

Work Highlights

Mr. De Ghenghi has advised financial institutions, private equity funds and investors in banks and investment banks on a variety of transactions and other matters including:

  • Morgan Stanley on its merger with E*TRADE
  • Ameriprise Financial on its rebanking through the conversion of its trust company into a federal savings bank
  • GE Capital on the rescission of its nonbank SIFI designation, as well as various asset sales following its 2015 restructuring
  • Strategic Growth Bank on its proposed merger of equals with Sunflower Bank, its spin-off of SG Capital Partners, and its acquisitions of Mile High Banks under Section 363 of the Bankruptcy Code and New Mexico Banquest
  • C1 Financial on its merger with Bank of the Ozarks, Inc.
  • China Cinda Asset Management Co., Ltd. on its acquisition of Nanyang Commercial Bank, Limited
  • Morgan Stanley on various non-controlling investments, its strategic alliance and Japanese securities joint venture with MUFG, and the spin-off of its in-house proprietary trading unit, Process Driven Trading (PDT)
  • Green Dot on its acquisition of Bonneville Bancorp and Loopt, and its acquisitions of assets and assumption of deposits from Synovus Financial Corp. and GE Capital Retail Bank
  • OneMain Financial on its acquisition by Springleaf
  • Mizuho Financial Group on the formation of Mizuho Americas, its intermediate U.S. bank holding company, and the merger of its two U.S. bank subsidiaries
  • Banco Santander on the formation of its intermediate holding company (IHC)
  • PIMCO on the formation of its $2.3 billion Bank Recapitalization and Value Opportunities (BRAVO) Fund
  • Lloyds Banking Group plc on its acquisition of HBOS plc
  • Sanpaolo IMI on the €65 billion merger between Sanpaolo IMI and Banca Intesa
  • Citizens Financial Group, Inc. and The Royal Bank of Scotland Group plc on Citizens’ $3.462 billion IPO and subsequent follow-on offerings
  • Agricultural Bank of China, Industrial and Commercial Bank of China and China Merchants Bank on their IPOs and the underwriters of China Construction Bank on its IPO
  • The underwriters on BankUnited, Inc.’s $900 million IPO
  • Citigroup, Inc. on its offering of $20.5 billion of new equity capital and debt securities in connection with its repayment of $20 billion of TARP trust preferred securities
  • Intesa Sanpaolo in connection with its multi-year criminal and civil investigation by the U.S. DOJ, the Manhattan DA’s office, and OFAC into alleged violations of U.S. economic sanctions.

From 1995 to 2001, he worked for J.P. Morgan in Brussels and London, where he became a managing director, head of the legal department for Europe, the Middle East and Africa, and member of the European Management Committee.


Mr. De Ghenghi has been recognized as a leading lawyer in various industry publications:

  • Chambers USA -- Leading Lawyer
  • Chambers USA -- Financial Services Regulation: M&A: Nationwide
  • Chambers USA -- Financial Services Regulation: Banking (Compliance): Nationwide, Band 1
  • IFLR1000 -- Leading Lawyer
  • Law360 -- "Banking MVP of the Year," 2016
  • The Best Lawyers in America -- "Financial Services Regulation Law," 2018

Of Note

  • Thought Leader on Financial Regulation, Davis Polk FinReg Blog, read Mr. De Ghenghi's posts
  • Author, “The IHC Requirement and Enhanced Prudential Standards for FBOs” (Chapter 6), Regulation of Foreign Banks and Affiliates in the United States (9th ed.)
  • Co-Author, “Foreign Bank Acquisitions of U.S. Banks and Thrifts” (Chapter 2), Regulation of Foreign Banks and Affiliates in the United States (9th ed.)
  • Author, “United States” (Chapter 41), The Banking Regulation Review (7th ed.)

Professional History

  • Partner, 2006-present
  • Counsel, Davis Polk, London office, 2001-2006
  • Managing Director, J.P. Morgan (Brussels and London), 1995-2001
  • Associate, Cleary Gottlieb Steen & Hamilton, 1990-1995
  • Associate, Davis Polk, 1985-1989

Bar Admissions

  • State of New York
  • U.S. Court of Appeals, Sixth Circuit
  • U.S. District Court, E.D. New York
  • U.S. District Court, S.D. New York


  • B.A., McGill University, 1980
    • with great distinction
  • B.A., Law, University of Oxford, 1982
    • Wadham College
  • J.D., Northwestern University Pritzker School of Law, 1985
    • cum laude
    • Articles Editor, Northwestern University Law Review


  • French
  • Italian