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For many asset-based lenders (“ABLs”) that do not take deposits, CRD VI’s branch requirements will not apply directly — but reliance on the non-bank carve-out requires careful, structure-specific analysis, and does not eliminate all regulatory risk.

General

CRD VI (Directive 2024/1619) introduces an EU-wide framework governing how non-EU undertakings may provide core banking services to EU borrowers. Article 21c requires third-country undertakings providing core banking services (including lending) within a Member State to establish a branch authorised under the Directive (a “third-country branch”). CRD VI applies primarily to “credit institutions” as defined under the Capital Requirements Regulation (“CRR”). The regime sits alongside existing national licensing frameworks. It should also be noted that CRD VI introduces other obligations (including ESG risk management and governance requirements) beyond the scope of this note.

Continue Reading CRD VI: New Rules for Cross-Border Lending into Europe — Why the Non-Bank Carve-Out Matters, but Is Not the Full Story

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

In an effort to improve market efficiency and to speed settlement, the Loan Syndications and Trading Association (the “LSTA”) has amended its trading documents in order to address concerns that market participants are increasingly failing to make timely payment of the “Purchase Price” with respect to their bank loan trade settlements. Although typically only one or two days late, some delays have been substantially longer, and such failures can understandably prove to be quite costly to loan sellers and disruptive to the market as a whole. The amendments introduce language into the LSTA Standard Terms and Conditions for its suite of trade confirmations (the “Standard Terms”) that requires tardy loan buyers to pay a “Late Payment Fee.” *

Continue Reading LSTA Introduces Late Payment Fees for Loan Trade Transactions

Crowell is proud to serve as a sponsor of and speaker at the American Conference Institute (ACI) 20th annual flagship conference on economic sanctions enforcement and compliance over April 29-30, 2026. Crowell partner and co-chair of the Financial Services group, Carlton Greene, spoke at the conference on “Latin America Under Scrutiny: Mitigating the Expanding Cross-Industry…

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

Crowell was pleased to host and sponsor Opus Connect’s recent NYC Private Debt Roundtable. The event drew a group of private debt leaders for engaging and thoughtful discussion around some of the key challenges private debt firms face today, and the emerging opportunities. The conversation covered everything from new technologies shaping the space to how firms are evolving their strategies in response to a changing environment.

Continue Reading Crowell Hosts NYC Private Debt Roundtable With Opus Connect

Crowell was proud to serve as a sponsor of the recent Drinks & Discussion hosted by the International Legal Finance Association (ILFA). The event on April 16 brought together over 150 leading practitioners, funders, and professionals from across the legal finance ecosystem at Grand Brasserie for networking and discussion on one of the most dynamic and rapidly evolving areas of finance.

Crowell has a leading Financial Services group, and is pleased to support the mission of ILFA through our sponsorship.

Continue Reading Crowell Sponsors ILFA Drinks & Discussion in New York

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…