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.

On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule that, for the first time, gives the term “unsafe or unsound practice” a binding regulatory definition.[1] With it came a uniform standard for Matters Requiring Attention (MRAs) and revised OCC examination manuals.[2]The Federal Reserve did not join the rulemaking, but has adopted comparable standards through guidance. What that means for holding companies and state-chartered institutions is addressed below.[3] The regulation takes effect November 2, 2026, and the revised OCC examination manuals took effect upon their issuance on August 27.

Over the past 18 months, the federal banking agencies have clarified supervisory expectations for banks’ crypto-asset activities, and several of the largest U.S. banks have announced programs accepting Bitcoin and Ether as loan collateral. Separately, on June 3, 2026, New York’s enactment of the 2022 amendments to the Uniform Commercial Code took effect, changing the rules governing the perfection of a security interest in digital asset collateral in New York, the jurisdiction whose law governs most institutional credit documentation. Together, these developments may create significant opportunities for lenders navigating the complexities to comply with the newly enacted statutes. This alert surveys the current landscape, from regulatory permissibility and perfection through custody, structuring, and compliance, for institutions active in this market or considering entering it.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold.

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.