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Anand Sithian

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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.

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Key Takeaway

On September 2, 2026, the Federal Reserve, FDIC, NCUA, OCC, and FinCEN confirmed that a bank may tell a customer that an account restriction or closure, or a rejected deposit, may be related to suspected fraud or other suspicious activity, so long as the communication does not reveal that a SAR was or will be filed.

What Happened

On September 2, 2026, the Federal Reserve, the FDIC, the NCUA, the OCC, and FinCEN issued a joint statement on the application of SAR confidentiality to banks’ communications with their customers (Joint Statement). The Bank Secrecy Act prohibits a bank from disclosing a suspicious activity report or any information that would reveal that one exists, and in particular from notifying any person involved in a transaction that the transaction has been reported. In practice, those prohibitions have led many banks to say nothing at all when a payment is held, a deposit is rejected, or an account is closed and the customer asks why. The Joint Statement confirms that the SAR confidentiality prohibitions are narrower than that practice: the regulators confirmed that a bank may communicate with a customer about potentially fraudulent transactions, other suspicious activity, or account closures, provided the communication does not reveal the existence of a SAR. The Joint Statement responds to comments on the agencies’ payments fraud initiative and invokes Executive Order 14331 on fair banking.

Continue Reading You Can Say More Than You Think: Regulators Clarify SAR Confidentiality for Customer Communications

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.

For boards, general counsel, and risk and compliance leaders, the headlines suggest clarity and potential relief. However, while the rule changes what federal bank examiners may require to bring enforcement, it does not change the standards of prudent risk management a bank is held to, the discretion examiners keep over ratings, or the exposure that sits with state supervisors, the holding company, and individual officers and directors. This client alert explains what changed and how to consider responding.

Continue Reading OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks

Key Takeaway: Domestic reporting companies—meaning entities formed under the laws of any U.S. state or Tribal jurisdiction—have no beneficial ownership information reporting obligations to FinCEN under the final rule.

What happened: On August 14, 2026, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule revising its previous rules implementing the Beneficial Ownership Information (“BOI”) reporting requirements of the Corporate Transparency Act (“CTA”). The final rule is effective immediately. The final rule makes permanent, and modestly expands, the relief first introduced by FinCEN in its March 26, 2025 interim final rule, which exempted domestic reporting companies (i.e., U.S.-formed entities) from any obligation to report BOI to FinCEN, and exempted foreign reporting companies from any obligation to report BOI with respect to U.S.-person beneficial owners. FinCEN also has said that it will delete the identifying information that companies reported to it about U.S.-person beneficial owners and company applicants, as well as persons who requested a “FinCEN ID” to aid BOI filings. In addition to the rule itself, FinCEN issued related FAQs. FinCEN cited issues of privacy, burden, and the ability to obtain information on the beneficial owners of U.S. companies as reasons for the final rule.

Continue Reading FinCEN Finalizes BOI Reporting Rule: What U.S. Companies Need to Know

What You Need to Know

Key takeaway #1: Bank regulators have shifted from prior approval to examination scrutiny. Banks no longer need supervisory nonobjection to lend against crypto collateral. Regulators are likely to focus their examinations on collateral operations, BSA/AML and sanctions compliance, and third-party risk management.

Key takeaway #2: Control-based perfection trumps filing, with a June 3, 2027, New York deadline to re-perfect existing security interests. Under the 2022 UCC amendments, a security interest in controllable electronic records perfected by control as of June 3, 2027, will have priority over a filing-only perfection, regardless of timing. Lenders relying on filing alone should consider taking steps to comply with UCC Article 12’s control arrangements before the adjustment date.

Key takeaway #3: Custody terms determine ownership in insolvency. Documents that permit a custodian or platform to use or rehypothecate pledged assets may impair the secured nature of a claim, leaving the lender with an unsecured one. Parties should confirm segregation, retained borrower title, and a prohibition on rehypothecation in custody documentation.

Key takeaway #4: Bankruptcy safe harbors may not apply; margin mechanics are the practical protection. Because spot crypto lending may fall outside the Bankruptcy Code’s safe harbors, conservative advance rates and market-based loan-to-value triggers are the principal protections.

Key takeaway #5: No capital recognition for digital asset collateral, and state licensing may apply. Digital asset collateral currently earns no credit risk mitigation relief under U.S. capital rules, and nonbank lenders may face state licensing obligations.

Continue Reading Lending Against Digital Assets: Five Key Takeaways for Lenders After a Year of Regulatory and UCC Change

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

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 Gap

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 Controls

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 Obligations

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.
Continue Reading OFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border 

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…