On June 4, 2026, Crowell partners Caroline Brown and Anand Sithian hosted the ACSS New York Chapter at the firm’s New York office for a panel discussion titled “Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals.” The sold-out event brought together practitioners from the financial crime compliance community for a timely and substantive conversation at the intersection of sanctions, narcotics trafficking, and AML risk.
Continue Reading Crowell Hosts ACSS New York Chapter Event on Cartels, Foreign Terrorist Organizations, and Financial Crime Compliance
Anand Sithian
For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.
A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.
Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.
Drift Protocol Exploit: Why “Social Trust” Is the Newest Cybersecurity Gap
What You Need to Know
- Key takeaway #1: Threat actors are no longer just looking for software bugs; they are spending months building fake identities to “befriend” organizations and conduct corporate espionage.
- Key takeaway #2: The Drift incident reflects a familiar Democratic People’s Republic of Korea (DPRK) playbook with an in-person twist: identity deception, relationship-building, privileged access, and rapid monetization ― the same methods central to North Korea’s remote IT worker schemes.
- Key takeaway #3: Where a small group of individuals can authorize consequential financial or administrative actions, social engineering and insider-enabled compromise present significant legal, compliance, and operational risk. High-risk approvals, access governance, and hiring controls should be treated as core security measures.
The recent $285 million theft from Drift Protocol serves as a high-stakes reminder that the human element remains one of the biggest cybersecurity gaps in any organization. This was not a “hack” in the traditional sense of breaking through a digital wallet. North Korean actors used sophisticated social engineering to exploit human trust ― highlighting what looks like a “hacking” risk into valuable lessons learned for cybersecurity oversight.
Continue Reading Drift Protocol Exploit: Why “Social Trust” Is the Newest Cybersecurity GapCrowell Sponsors ACSS Annual U.S. Conference on Global Sanctions and Export Controls
Crowell was proud to serve as a sponsor of and speaker at the recent Association of Certified Sanctions Specialists (ACSS) annual U.S. conference on global sanctions and export controls. Crowell partners Anand Sithian and Caroline Brown spoke at the conference. Anand spoke on “The After-Action Review of Recent Sanctions and Export Controls Enforcement Actions,” and Caroline spoke on “The New War on Drugs: Cartels, and Transnational Criminal Organizations.”
The event brought together leading government officials and industry specialists for insight and practical guidance on today’s geopolitical, sanctions, and export controls landscape and the most pressing compliance challenges.
Continue Reading Crowell Sponsors ACSS Annual U.S. Conference on Global Sanctions and Export ControlsOFAC Expands Venezuela Sanctions Relief: New General Licenses 56 and 57, and Guidance on Reporting Obligations
On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL 57). OFAC also issued one Venezuela-related Frequently Asked Question (FAQ), FAQ 1248.
These actions represent the latest steps in a continuing U.S. policy of progressively opening channels for commercial and financial engagement with Venezuela, extending the series of general licenses that OFAC has issued since early 2026 across the energy, petrochemical, minerals, and infrastructure sectors.
Continue Reading OFAC Expands Venezuela Sanctions Relief: New General Licenses 56 and 57, and Guidance on Reporting ObligationsOFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border
Key Takeaways
- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border.
- OFAC’s actions are the latest examples of a broader national security strategy to use sanctions, AML authorities, criminal prosecutions, and other tools to counter cartels on the U.S.-Mexico border. These efforts have targeted in particular non-traditional financial institutions such as casinos, public-facing professionals, and disinformation actors.
- The State Department designated CDN as a foreign terrorist organization (FTO) on February 20, 2026, and today’s designations were issued under both Executive Order 14059 (narcotics trafficking) and Executive Order 13224 (terrorism), underscoring the U.S. government’s treatment of major cartels as hybrid criminal-terrorist threats.
Crowell Publishes Article on New York Crypto Bill in Law360
On Jan. 14, New York state Sen. Zellnor Myrie proposed legislation in the New York State Senate that would amend New York law to make it a criminal offense to operate a virtual currency business in the state without the proper license.
By introducing the possibility of criminal penalties, S.B. 8901 — the Cryptocurrency Regulation…
CFTC Takes Additional Steps Toward Prediction Market Regulation: What You Need to Know
Overview
On March 12, 2026, the U.S. Commodity Futures Trading Commission (CFTC) took formal steps toward establishing additional regulations for prediction markets. The agency issued an Advanced Notice of Proposed Rulemaking (ANPRM) soliciting public input on potential new rules, and separately, released staff guidance outlining its views on how existing rules apply to prediction market platforms currently in operation. These developments signal a significant shift in the regulatory landscape for an industry that has grown rapidly over the past year.
Continue Reading CFTC Takes Additional Steps Toward Prediction Market Regulation: What You Need to KnowFinCEN Grants Exceptive Relief to Streamline Beneficial Ownership Verification Requirements for Financial Institutions
What You Need to Know
Key Takeaway #1: FinCEN will no longer require covered financial institutions to identify and verify beneficial owners of legal entity customers each time the customer opens a new account at the institution, but rather only in certain circumstances.
Key Takeaway #2: FinCEN will instead require certain financial institutions to identify and verify the identities of such beneficial owners: (1) when a legal entity customer first opens an account with a covered financial institution; (2) when the covered financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained about the legal entity customer; and (3) as needed based on a covered financial institution’s risk-based procedures for conducting ongoing customer due diligence. For (3), covered financial institutions may rely on the customer’s certification that its beneficial ownership information has not changed, unless there is reason to question this.
Key Takeaway #3: The exceptive relief is the latest instance of recent efforts by the Department of the Treasury to modernize and eliminate unnecessary burdens associated with BSA rules; covered financial institutions are likely to welcome the relief.
Continue Reading FinCEN Grants Exceptive Relief to Streamline Beneficial Ownership Verification Requirements for Financial InstitutionsProposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto Firms
On January 14, 2026, State Senator Zellnor Myrie proposed legislation in the New York State Senate that would amend New York law to make it a criminal offense to operate a virtual currency business in New York without the proper license. By introducing the possibility of criminal penalties, Senate Bill S. 8901, the Cryptocurrency Regulation Yields Protections, Trust, and Oversight Act (CRYPTO Act), would mark a significant regulatory shift in the state’s oversight of virtual currency businesses, given New York’s prominence in virtual currency regulation in the U.S.
Continue Reading Proposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto FirmsCrowell & Moring Ranked a Leader for Crypto-Asset Disputes by Chambers FinTech
Crowell has been ranked a leading firm by Chambers FinTech in the USA Nationwide Crypto-Asset Disputes category. Crowell’s Anand Sithian has been named a notable practitioner in this area.
According to Chambers, Crowell’s FinTech practice has “strong corporate, financial services and white-collar capabilities to support clients across transactions and evolving regulatory frameworks.”
Chambers FinTech offers…