Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering (AML), the Bank Secrecy Act (BSA), U.S. economic sanctions, including those administered by the Office of Foreign Assets Control (OFAC), and asset forfeiture matters. Anand routinely counsels clients on the novel application of these laws and regulations to issues involving financial institutions, technology and social media, virtual currency and digital assets (including the seizure and forfeiture of virtual currencies), and the evolving cannabis industry.
Anand has extensive experience in white collar and regulatory enforcement defense and internal investigations and has represented companies and individuals before the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and the Federal Reserve Board (FRB).
Anand’s experience includes litigating a wide range of complex civil and criminal matters, including antitrust class actions, securities litigation, white-collar defense and internal investigations, as well as advising on AML, BSA, and economic sanctions issues.
Government Service
Following law school, Anand joined the DOJ through the Attorney General’s Honors Program and served as a trial attorney in the Criminal Division’s Money Laundering and Asset Recovery Section (MLARS). While at the DOJ, Anand investigated and prosecuted a wide array of matters involving asset forfeiture, money laundering, AML compliance, the BSA, and economic sanctions.
Speeches & Presentations
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"Introduction to Cryptocurrency & NFTs," Hispanic National Bar Association / Intellectual Property Law Institute Conference Panel
(June 10, 2022).
Speakers: Jesse Camacho, Anand Sithian, and James Gatto.
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"Analysis of the Evolving US Sanctions on Russia and the Impact on the Loan Market," LSTA University Webinar 2022.
(March 9, 2022).
Speakers: Caroline E. Brown, Dj Wolff, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Robert Clifton Burns.
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"Russia-Related Sanctions Developments," Crowell & Moring Webinar
(March 2, 2022).
Speakers: Caroline E. Brown, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Lorenzo Di Masi, Anand Sithian, and Nicole Sayegh Succar.
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"Emerging Payments and Digital Assets: How to Identify and Mitigate Complex Sanction Challenges," ACI’s 15th Flagship Conference on U.S. Economic Sanctions
(December 7, 2021).
Speakers: Amir Fadavi, Court Hillman, Anand Sithian, and Ashleigh MacMartin.
Publications
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"Federal Banking Regulators Start 2023 By Highlighting Crypto-Related Risks," Crowell & Moring’s Crypto Digest
(January 9, 2023).
Author: Anand Sithian.
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"Sanctions/Export Highlights [As of November 03, 2022]" Crowell & Moring’s International Trade Law
(November 7, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, Anand Sithian, and Darianne Young.
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"FinCEN And U.S. Department Of Commerce Issue Joint Alert Highlighting Risks Of Export Control Violations For Financial Institutions," The Banking Law Journal
(November-December 2022).
Authors: Jeffery L. Snyder, Carlton Greene, Anand Sithian, Chandler S. Leonard, Jeremy Iloulian, and Jackie Schaeffer.
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"Russia Sanctions/Export Highlights [As of June 16, 2022]" Crowell & Moring’s International Trade Law Blog
(June 16, 2022).
Authors: Frances P. Hadfield, Anand Sithian, and Rachel Schumacher.
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"Sanctions/Export Highlights [As of May 26, 2022]" Crowell & Moring’s International Trade Law
(May 27, 2022).
Authors: Anand Sithian and Rachel Schumacher.
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"Sanctions/Export Highlights [As of May 6, 2022]" Crowell & Moring’s International Trade Law Blog
(May 6, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, Michelle Linderman, Caroline Brown, Nicole Succar, Anand Sithian, Brian McGrath, Laurel Saito, and Rachel Schumacher.
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"Russia Sanctions/Export Highlights [As of April 28, 2022]" Crowell & Moring’s International Trade Law Blog
(April 28, 2022).
Authors: Caroline Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Laurel Saito, and Rachel Schumacher.
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"Sanctions/Export Highlights [As of April 7, 2022]" Crowell & Moring’s International Trade Law
(April 8, 2022).
Authors: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Edward Goetz and Laurel Saito.
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"Sanctions/Export Highlights [As of March 31, 2022]" Crowell & Moring’s International Trade Law
(April 1, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, Anand Sithian and Laurel Saito.
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"Update: Expanded U.S. Ban on Russian Imports and Russia’s Removal from Permanent Normal Trade Relations Status," Crowell & Moring’s International Trade Law
(March 29, 2022).
Authors: John B. Brew, David (Dj) Wolff, Maria Vanikiotis, Frances P. Hadfield, Anand Sithian and Chandler S. Leonard.
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"Russia Sanctions/Export Highlights [As of March 10, 2022]" Crowell & Moring’s International Trade Law
(March 12, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, David (Dj) Wolff, Michelle J. Linderman, Nicole Sayegh Succar, Anand Sithian, Brian McGrath, Laurel Saito and Rachel Schumacher.
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"Breaking News: Expanded U.S. Ban on Russian Imports and Russia’s Removal from Permanent Normal Trade Relations Status," Crowell & Moring’s International Trade Law
(March 11, 2022).
Authors: John B. Brew, David (Dj) Wolff, Maria Vanikiotis, Anand Sithian, Frances P. Hadfield and Chandler S. Leonard.
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"One Year Later: Addressing Whistleblower Risks Under The AMLA," New York Law Journal
(January 31, 2022).
Authors: Daniel L. Zelenko, Carlton Greene, Anand Sithian, Danielle Giffuni, and Collen Johnson.
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register," The Banking Law Journal
(December 6, 2021).
Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Christopher Murphy.
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"Preparing For The ‘Surge’: Enhanced Corporate Enforcement," Westlaw Today
(October 20, 2021).
Authors: Thomas A. Hanusik, Evan Y. Chuck, Anand Sithian, Sarah Bartle.
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"Office of Foreign Assets Control (OFAC) Issues License For the U.S. Government and U.S. Government Contractors for Humanitarian Assistance in Afghanistan," Crowell & Moring’s International Trade Law
(September 22, 2021).
Authors: Jeffrey L. Snyder, Frances P. Hadfield, Anand Sithian, Nicole Sayegh Succar and Martín Yerovi.
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"New York Governor Kathy Hochul Announces Nomination of Adrienne Harris as Superintendent of the New York Department of Financial Services," Crowell & Moring’s International Trade Law
(September 2, 2021).
Authors: Caroline E. Brown, Carlton Greene, Anand Sithian, Frances P. Hadfield and Martín Yerovi.
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"FinCEN Issues Major Anti-Money Laundering Act Announcements And Appoints New Chief Digital Currency Advisor," Westlaw Today
(July 30, 2021).
Authors: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Anand Sithian.
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"Treasury Secretary Janet Yellen to Hold a Meeting of the President’s Working Group on Financial Markets (PWG) to Discuss Stablecoins," Crowell & Moring’s International Trade Law
(July 19, 2021).
Authors: Anand Sithian, Michelle Ann Gitlitz, Frances P. Hadfield and Martín Yerovi.
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"U.S. Government Issues Business Advisory – Warns Companies About Risks of Doing Business in Hong Kong," Crowell & Moring’s International Trade Law
(July 16, 2021).
Authors: Caroline E. Brown, Evan Y. Chuck, David (Dj) Wolff, Anand Sithian, Frances P. Hadfield and Martín Yerovi.
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"Agency Issues First National Priorities for Anti-Money Laundering and Counter-Terrorist Financing, Completes Assessment on Potential No-Action Letter Process, Provides 180-Day Update on AML Act Implementation, and Appoints First-Ever Chief Digital Currency Advisor," Crowell & Moring’s International Trade Law
(July 15, 2021).
Authors: Caroline E. Brown, Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian and Nicole Sayegh Succar.
Client Alerts & Newsletters
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"The Month in International Trade – January 2023,"
International Trade Bulletin
(February 8, 2023).
Contacts: Maria Alejandra (Jana) del-Cerro, Anand Sithian, Simeon Yerokun, Edward Goetz
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"The Month in International Trade – December 2022,"
International Trade Bulletin
(January 9, 2023).
Contacts: Maria Alejandra (Jana) del-Cerro, Anand Sithian, Simeon Yerokun, Edward Goetz
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"The Month in International Trade – November 2022,"
International Trade Bulletin
(December 6, 2022).
Contacts: Maria Alejandra (Jana) del-Cerro, Anand Sithian, Simeon Yerokun, Edward Goetz
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"The Month in International Trade – October 2022,"
International Trade Bulletin
(November 9, 2022).
Contacts: Maria Alejandra (Jana) del-Cerro, Anand Sithian, Simeon Yerokun, Edward Goetz
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"The Month in International Trade – September 2022,"
International Trade Bulletin
(October 5, 2022).
Contacts: Maria Alejandra (Jana) del-Cerro, Anand Sithian, Simeon Yerokun, Edward Goetz
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"The Month in International Trade – August 2022,"
International Trade Bulletin
(September 8, 2022).
Contacts: Jeffrey L. Snyder, Anand Sithian, Edward Goetz
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"Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers,"
International Trade Bulletin
(August 17, 2022).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Jackie Schaeffer
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"FinCEN and the U.S. Department of Commerce Issue Joint Alert Highlighting Risks of Export Control Violations for Financial Institutions,"
International Trade Bulletin
(July 13, 2022).
Contacts: Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Chandler S. Leonard, Jeremy Iloulian, Jackie Schaeffer
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"DOJ’s Revised Prosecutorial Guidelines: The “Ethical” Hacker Exemption,"
Privacy Law Alert
(June 3, 2022).
Contacts: Nimrod Haim Aviad, Stephen M. Byers, Matthew B. Welling, Evan D. Wolff, Alexander Urbelis, Anand Sithian
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"New Law Gives NYDFS Authority to Make Virtual Currency Business Activities in New York More Expensive,"
Privacy Law Alert
(May 11, 2022).
Contacts: Garylene (Gage) Javier, CIPP/US, Anand Sithian, Carlton Greene, Caroline E. Brown, Kelly T. Currie, Nicole Sayegh Succar
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"Financial Institutions Beware: FDIC Requests “Prompt” Notice of Crypto-Related Activities,"
Financial Services Alert
(April 20, 2022).
Contacts: Carlton Greene, Caroline E. Brown, Stephanie L. Crawford, Alexander Urbelis, Anand Sithian
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"President Biden Issues Executive Order Directing “Whole of Government” Assessment of Digital Assets,"
Financial Services Alert
(April 5, 2022).
Contacts: Alexander Urbelis, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown, Richard J. Lee, Irina Pisareva, Carlton Greene
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"SEC Announces 2022 Examination Priorities,"
Financial Services Alert
(April 1, 2022).
Contacts: Carlton Greene, Anand Sithian, Irina Pisareva, Richard J. Lee, Nimrod Haim Aviad, Caroline E. Brown, Alexander Urbelis
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"U.S., EU and UK Escalate Belarus Sanctions,"
International Trade Bulletin
(December 15, 2021).
Contacts: Carlton Greene, Michelle J. Linderman, Nicole Sayegh Succar, Anand Sithian, David (Dj) Wolff, Caroline E. Brown
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"Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics,"
International Trade Bulletin
(November 15, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Sarah Bartle, Anand Sithian, Nicole Sayegh Succar
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"Stablecoin Regulation Is Coming? President’s Working Group Issues Report on Stablecoins Outlining Stablecoin Risks and Requesting Congress Pass Urgent Legislation Regulating Stablecoins,"
Blockchain Alert
(November 15, 2021).
Contacts: Carlton Greene, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown
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"Preparing for the “Surge”: Enhanced Corporate Enforcement is Coming,"
White Collar Alert
(October 12, 2021).
Contacts: Thomas A. Hanusik, Evan Y. Chuck, Anand Sithian, Sarah Bartle
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"OFAC Issues Updated Guidance on Ransomware Attacks and Imposes First Sanctions Designation on a Virtual Currency Exchange,"
International Trade Bulletin
(September 28, 2021).
Contacts: Caroline E. Brown, Laura Foggan, Carlton Greene, Jeffrey L. Poston, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner, Alexander Urbelis, Anand Sithian, Matthew B. Welling, Rebecca Lennon Baskin
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"Blockchain Solutions Launched by European Nuclear Pools,"
Insurance/Reinsurance Alert
(September 9, 2021).
Contacts: Laura Foggan, Mark Meyer, Anand Sithian, Kelly H. Tsai
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register,"
Financial Services Alert
(August 25, 2021).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Chris Murphy
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"FinCEN Issues Major Anti-Money Laundering Act Announcements and Appoints New Chief Digital Currency Advisor,"
Financial Services Alert
(July 14, 2021).
Contacts: Caroline E. Brown, Kelly T. Currie, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian, Nicole Sayegh Succar
Press Coverage
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Why Proof of Innocence Won’t Work For US Tornado Cash Users
January 28, 2023 — Blockworks
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Can You Buy Bitcoin Without An Exchange Like FTX? We Tried.
November 25, 2022 — Barron's
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US Prosecutors Opened Probe of FTX Months Before Its Collapse
November 21, 2022 — Bloomberg
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Bittrex Fines A Sign Of More To Come
October 14, 2022 — Global Investigations Review
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A Legal Insight Into Whether Crypto Sanctions Going Too Far? – SlateCast #22
October 3, 2022 — CryptoSlate
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Crypto Firms Could Face Fallout From SEC Insider Trading Case Against Former Coinbase Employee
July 22, 2022 — The Block
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Treasury, Commerce Alert May Lead To More Diligence Steps, Affect Disclosures, Law Firm Says
July 14, 2022 — Export Compliance Daily (subscription required)
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Immunity Deal For Yacht Company Reveals US Strategy For Oligarch Probes
June 24, 2022 — Global Investigation Review
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SEC’s New Crypto Enforcers Are Coming For DeFi, Lawyers Say
June 14, 2022 — CQ Roll Call
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Sanctions Threaten To Cripple Russia’s Multibillion-Dollar Crypto Industry
April 22, 2022 — CNBC
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Sanctioning An Ether Address Isn't Stopping Transactions
April 22, 2022 — CoinDesk
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Former Fox Director Indictment Illustrates DOJ’s Tough Approach To Russia Sanctions
March 10, 2022 — Global Investigations Review (subscription required)
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First Year Into AMLA – What Has Been Done And What To Expect?
February 7, 2022 — VIXIO Regulatory Intelligence (subscription required)
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Systemic Risk Seen As Potential Route To Stablecoin Regulation
January 11, 2022 — Roll Call
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Pandora Papers Reveal Further Gaps In U.S. AML Rules
October 15, 2021 — VIXIO Payment Compliance
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FinCEN Stretches Regulatory Reach To Foreign Crypto-Exchanges
August 12, 2021 — VIXIO (subscription required)