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Carlton Greene

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Carlton Greene is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm's International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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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 Institutions

Key Takeaways:

  1. The Russian Federation, Bolivia and the British Virgin Islands (“BVI”) have been added to the EU list of third countries deemed high risk for AML/CTF purposes.
  2. The EU has removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania from this list.
  3. The EU’s position redefines the risk landscape for entities with exposure to Russian, Bolivian, and BVI organisations or individuals, and consequently increases commercial pressure on EU/Russian relationships with extensive global sanctions already imposed due to the ongoing Russia/Ukraine conflict.

Continue Reading EU Amendments to List of High-Risk AML/CTF Countries

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 Firms

On December 19, 2025, New York Governor Kathy Hochul vetoed a bill that would have amended the New York LLC Transparency Act (“New York Act”) to include beneficial ownership information (“BOI”) reporting requirements for all non-U.S. and U.S. limited liability companies (“LLCs”) registered to do business in New York State (“New York”).

The Governor’s veto means that the New York Act willonly require disclosure of BOI only for non-U.S. LLCs registered to do in business in New York that do not otherwise qualify for any of the exemptions in the New York Act, and only with respect to non-U.S. beneficial owners.Continue Reading Governor’s Veto Limits Scope of New York LLC Transparency Act to Foreign LLCs Registered in New York

Yesterday, FinCEN announced an ongoing enforcement initiative against more than 100 money services businesses (“MSBs”) operating along the Southwest U.S. border. FinCEN says that it reviewed over one million currency transaction reports (“CTRs”) and 87,000 suspicious activity reports (“SARs”) using new data processing techniques to identify potential Bank Secrecy Act (“BSA”) compliance concerns with MSBs there. The agency says this resulted in six FinCEN Notices of Investigation, “dozens” of referrals to the IRS, and 50 compliance outreach letters. An accompanying video from Treasury Secretary Scott Bessent suggests that the initiative is intended to “stop terrorist cartels, drug traffickers, and human smugglers” and to “root out potential cartel-related money laundering from the U.S. financial system.”Continue Reading FinCEN Announces Enforcement Initiative for MSBs Along the Southwest Border

On January 1, 2026, the New York LLC Transparency Act is scheduled to take effect, introducing new disclosure requirements for limited liability companies in New York State.

The legislation will have significant implications for all LLCs formed or registered to do business in New York. Furthermore, a proposed amendment awaiting the Governor’s signature would broadly…

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…

On November 13, 2025, the U.S. Department of the Treasury’s (“Treasury’s”) Financial Crimes Enforcement Network (“FinCEN”) issued a finding (“Finding”) and related notice of proposed rulemaking (“Proposed Rule”) pursuant to Section 311 of the USA PATRIOT Act (“Section 311”), targeting ten Mexico-based gambling establishments (“Gambling Establishments”).  FinCEN found transactions involving the Gambling Establishments to constitute a “class of transactions” of “primary money-laundering concern” for purposes of Section 311.  In particular, FinCEN found that the Gambling Establishments ultimately were controlled by a criminal group that used the establishments to facilitate money laundering for the Sinaloa Cartel.…

Continue Reading Treasury Continues Focus on Cartels: Understanding FinCEN’s Latest Action Restricting Transactions with Certain Mexico-Based Gambling Establishments

Banks and other regulated financial institutions have been digesting a set of four frequently asked questions (“FAQs”) about suspicious activity reports (“SARs”) issued jointly on October 9, 2025 by FinCEN and federal banking regulators (the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration). According to remarks the same day from Treasury Secretary Scott Bessent, the FAQs are intended to reduce the compliance burdens associated with filing SARs without diminishing the benefit of SAR reporting to law enforcement.Continue Reading FinCEN and Banking Regulators Issue New FAQs on Suspicious Activity Reports

On Wednesday, November 5, the U.S. Supreme Court will hear arguments on whether President Trump’s tariffs—imposed under the International Economic Emergency Powers Act (IEEPA) —were legal. The Court’s decision will have significant impacts for importers, as well as investors in the IEEPA tariff claims. Many investors have participated in the growing secondary market, in which…