Financial Services
Overview
Protecting the businesses that strengthen economies
Crowell’s financial services team represents many of the world’s leading multinational banks, investment firms, private-equity houses, brokerage firms, hedge funds, trading associations, and related businesses and organizations, advising them on complex transactions, regulatory enforcement, and litigation. We also counsel non-financial institutions on their unique financial needs ranging from management of their loan facilities to FinTech and beyond.
Contacts
Insights
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.
Publication | 07.22.25
Government Contracts And The Risks Of Bankruptcy In The Current Environment
Publication | 07.16.25
The Rise Of Technology: Using Section 236 In The Digital Era (UK)
Insights
Personae Non Gratae In The Loan Market: Trading Considerations For Disqualified Institutions
|07.23.25
The Banking Law Journal
Government Contracts And The Risks Of Bankruptcy In The Current Environment
|07.22.25
Briefing Papers
The Rise Of Technology: Using Section 236 In The Digital Era (UK)
|07.16.25
The Journal of Bankruptcy Law
Chasing Carrots: The Uncertain Rewards Of SEC Self-Reporting And Cooperation
|07.05.24
New York Law Journal
The Secret Sauce For Successful Bankruptcies Requires The Right Ingredients
|07.20.23
Journal of Corporate Renewal
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11.01.22
The Banking Law Journal
Challenges Of The Amended Form PF June 12, 2025, Compliance Deadline
|04.24.25
Hedge Fund Law Report
Damaging SEC Staff Bulletin that Undermined Digital Assets, SAB 121, Revoked
|01.23.25
Crowdfund InsiderTreasury Already Seeking Comments On The Outbound Investment Regime
|08.14.23
Foreign Investment Watch
2024 ACAMS The Assembly Hollywood Conference
|04.08.24 - 04.10.24
"Changing Sanctions: How to Stay Ahead?" NICE Actimize Engage Conference
|06.04.24
ACAMS Masterclass: The Threat from Within a Financial Institution
|05.17.24
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09.01.23
Crowell & Moring’s Crypto Digest
Bittrex: Regulatory Enforcement and Macroeconomic Headwinds Lead to Another Crypto Bankruptcy
|05.23.23
Crowell & Moring’s Crypto Digest
Crypto Trader’s “Profitable Trading Strategy” Appears to be Mere Market Manipulation
|01.30.23
Crowell & Moring’s Crypto Digest
Earn Accounts are Property of the Estate: Celsius Update
|01.17.23
upCrowell & Moring’s Crypto Digest
- |
12.12.22
Crowell & Moring's Crypto Digest
Professionals
Insights
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.
Publication | 07.22.25
Government Contracts And The Risks Of Bankruptcy In The Current Environment
Publication | 07.16.25
The Rise Of Technology: Using Section 236 In The Digital Era (UK)
Practices
Contacts
Insights
Client Alert | 4 min read | 08.06.25
FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers
Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.
Publication | 07.22.25
Government Contracts And The Risks Of Bankruptcy In The Current Environment
Publication | 07.16.25
The Rise Of Technology: Using Section 236 In The Digital Era (UK)