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.
FinCEN and Banking Regulators Issue New FAQs on Suspicious Activity Reports
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
Investors Anticipate Supreme Court Arguments on Trump’s Tariff Powers
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
Welcome to FinTalk!
On behalf of the entire Financial Services Group, welcome to FinTalk! FinTalk is the new flagship blog from Crowell & Moring’s Financial Services Group.
Drawing on the deep transactional and regulatory industry experience of our firm’s financial services attorneys, FinTalk delivers timely updates on the ever-evolving financial services landscape.
Across finance, regulatory, debt and claims
Crowell & Moring Shortlisted by ILFA for “Exceptional Legal Services Provider for Litigation Funders (US-based)” Award
Crowell has been shortlisted for “Exceptional Legal Services Provider for Litigation Funders (US-based)” by the International Legal Finance Association for its inaugural Legal Finance Awards.
The award recognizes law firms that provide direct and invaluable support to funders in creating deals, portfolio management, and other operational outputs, with a strong reputation in the sector for
Asset Based Finance Lawyer Tom Dell’Avvocato Joins Crowell & Moring in London
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.Continue Reading Asset Based Finance Lawyer Tom Dell’Avvocato Joins Crowell & Moring in London
Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group