Insights

London – September 11, 2025: Tom Dell’Avvocato has joined Crowell & Moring U.K. LLP as a partner in its Financial Services Group. Dell’Avvocato brings extensive experience in non-contentious banking and finance transactions, with a focus on domestic and cross-border asset-based lending, as well as leveraged and specialty finance. He advises alternative and private capital providers, bank and non-bank lenders, and corporate borrowers on the structuring, restructuring, and execution of complex financing arrangements. 

Washington – June 26, 2025: Crowell & Moring has been recommended in eight practice areas in the 18th edition of the Legal 500 United States. In addition, partner Daniel Forman, co-chair of the firm’s Government Contracts Group, has been named to the Legal 500’s “Hall of Fame” for Government Contracts.

U.S. Government and private sector sources continue to report efforts by Democratic People’s Republic of Korea (DPRK) nationals to infiltrate companies around the world by posing as information technology (IT) professionals, in order to get hired by U.S. and other businesses and gain access to sensitive company systems. Crowdstrike, a U.S. cybersecurity company, has reported a 220% increase in the number of companies infiltrated by North Korean threat actors over the last 12 months. In particular, a DPRK-affiliated group known as “Famous Chollima” has leveraged artificial intelligence and deepfake technology to generate synthetic identities, as well as resumes and CVs, draft communications, and conduct job interviews. Enforcement actions brought by the U.S. Department of Justice identify victims in the cryptocurrency sector, including decentralized finance (“DeFi”) projects. In addition, media reports indicate that North Korean hackers are purportedly offering fake job offers targeting employees in the cryptocurrency sector, with the goal of stealing crypto.

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.  

 

On October 12-13, Crowell is proud to sponsor ACI's first Forum on Digital Assets Compliance: AML, Sanctions & Fraud. Carlton Greene, chair of Crowell's Financial Services practice, will be moderating an in-house executive roundtable discussing Perspectives on Managing the Latest Emerging Opportunities and Risks Confronting the Crypto Industry. Key discussion areas for the panel will include:

On January 7, 2020, the OCIE of the Securities and Exchange Commission, responsible for overseeing investment advisers, broker-dealers and others, announced its 2020 examination priorities. We will review these priorities, with special attention paid to financial technology and innovation, including digital assets and anti-money laundering (AML) programs.

Carlton Greene will be speaking on a panel. The topic: "AML/Sanctions Regulation and Enforcement Update." This panel reviews recent developments and changes in the anti-money laundering and sanctions compliance landscape.

Thursday, October 10, 2024Understanding FinCEN's Final Rule: AML/CFT Compliance for Investment AdvisersClick here to view the on-demand webinar program.On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that will impose new anti-money laundering and countering the financing of terrorism (AML/CFT) requirements on SEC-registered investment advisers and exempt reporting advisers. Join us for an insightful webinar on the new regulatory requirements issued by FinCEN. This session will provide a comprehensive overview of the specific requirements for AML/CFT compliance programs, as well as key takeaways and issues to keep top of mind as we move into this new enforcement era.

Please join us for a discussion to explore key issues in the business community as the war in Ukraine continues to reverberate through the global supply chain.

Crowell & Moring’s sanctions team provides guidance on the rapidly-changing U.S. sanctions against Russia, including measures against various Russian banks and Russia’s central bank, National Wealth Fund, and Ministry of Finance, and how these new sanctions can arise in syndicated loans and other lending arrangements, and loan trading.

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law and public policy as they impact our lives. In this podcast, hosts Nicole Simonian and Ambassador Robert Holleyman talk to Crowell & Moring Partners Dj Wolff and Carlton Greene, who both specialize in economic sanctions, about the U.S. and global economic response to the Russia-Ukraine conflict and the impact on global supply chain. Specifically, they will discuss what listeners should be looking out for, and help them expect the unexpected.