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Anand Sithian

Partner | He/Him/His
Partner | He/Him/His
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Areas of Focus

Overview

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.

He has represented both U.S. and foreign clients in a variety of investigations and regulatory matters before the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”), the U.S. Department of Justice (“DOJ”) (including a number of U.S. Attorney’s offices), banking agencies—including the Federal Reserve, and the New York Department of Financial Services (“NYDFS”)—and the U.S. Securities and Exchange Commission (“SEC”).  Anand routinely advises clients on asset forfeiture seizures and cases, including advising on recovery of seized assets on behalf of victims and third-parties.

Anand also closely partners with the firm’s leading Privacy and Cybersecurity group in advising clients on SEC enforcement and compliance considerations in connection with incident response and the SEC’s cybersecurity incident regulations.

Anand is a frequent writer and is often sought after for his insights on cutting-edge legal matters pertaining to digital assets. He is regularly quoted in media outlets including Bloomberg, CNBC, Barron’s, Coindesk, The Block, and Blockworks.

Government Service

Following law school, Anand joined the DOJ through the Attorney General’s Honors Program and served as a trial attorney in the Criminal Division’s Money Laundering and Asset Recovery Section (“MLARS”). While at the DOJ, Anand investigated and prosecuted a wide array of matters involving asset forfeiture, money laundering, AML compliance, the BSA, and economic sanctions.

Career & Education

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    • Department of Justice
      Trial Attorney, Criminal Division, Money Laundering and Asset Recovery Section, 2011–2014
      Special Assistant U.S. Attorney, U.S. Attorneys' Offices, District of Columbia, 2011–2012
      Special Assistant U.S. Attorney, Southern District of New York, 2013–2014
    • Department of Justice
      Trial Attorney, Criminal Division, Money Laundering and Asset Recovery Section, 2011–2014
      Special Assistant U.S. Attorney, U.S. Attorneys' Offices, District of Columbia, 2011–2012
      Special Assistant U.S. Attorney, Southern District of New York, 2013–2014

    • Tufts University, B.A., 2006
    • Emory University School of Law, J.D., with honors, 2011
    • Tufts University, B.A., 2006
    • Emory University School of Law, J.D., with honors, 2011

    • New Jersey
    • New York
    • New Jersey
    • New York

Anand's Insights

Client Alert | 4 min read | 12.19.24

DOJ Appeals Nationwide Preliminary Injunction of the Corporate Transparency Act, Seeks Stay of Injunction During its Appeal

As we discussed in our recent client alert, the U.S. District Court for the Eastern District of Texas issued an opinion and order on December 3, 2024, ("the Order") enjoining the federal government from enforcing the CTA and a rule implementing it. The rule requires certain entities formed or registered to do business in the U.S. ("reporting companies") to report information about themselves and their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury....

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Representative Matters

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Digital Assets / Blockchain / FinTech

  • Advised digital assets custodian in connection with limited purpose trust charter application (i.e., a “BitLicense”) to the NYDFS and engaged with NYDFS on regulatory questions.
  • Advising third-party market maker in connection with SEC enforcement investigation, compliance advice, and SEC enforcement action against token issuer.
  • Advising foreign crypto derivatives platform on sanctions and AML compliance, including drafting AML and sanctions compliance policies and procedures.
  • Advised digital assets payments platform on BSA/AML and sanctions risk assessment in connection with potential application to the OCC for a digital assets trust charter.
  • Advising venture capital arm of major token project on entry into the United States and related compliance considerations.
  • Advised non-fungible token (“NFT”) marketplace on digital assets / NFT insider trading policy.
  • Advised FinTech on BSA/AML considerations regarding customer rewards program and implications under FinCEN pre-paid access regulations.
  • Advised digital assets pre-paid card provider on AML and sanctions-related compliance.
  • Advised leading payments platform on AML questions regarding Suspicious Activity Reports (“SARs”), including use by affiliates and potential unauthorized SAR disclosure issues.
  • Advised FinTech lending platform on know-your-customer (“KYC”) obligations under OCC and FinCEN customer identification program (“CIP”) rules and guidance.

White Collar & Regulatory Defense

  • Representing the former CFO of a financial institution in connection with various federal regulatory inquiries and parallel civil lawsuits under the securities laws and related claims.
  • Representing the former CFO of a leading cryptocurrency trading and lending platform in connection with investigations by DOJ, the SEC, and the New York Attorney General (“NYAG”).
  • Representing the former Chief Compliance Officer of a peer-to-peer digital assets platform in a DOJ investigation.
  • Representing major technology company in connection with SEC investigation into a cybersecurity incident and related disclosure issues.
  • Representing leading athletic apparel company in connection with SEC investigation into executive perquisites, related party transactions, and compliance with Regulation S-K.
  • Advising various tech companies and government contractors on SEC cybersecurity incident matters, including SEC enforcement considerations around disclosure controls.
  • Advising, pro bono, individual charged by a U.S. Attorney’s Office (“USAO”) for conspiracy to commit wire fraud and money laundering, and identity theft in connection with government construction company contracts
  • Represented Asia-based consumer goods company in favorably resolving economic sanctions by the DOJ’s National Security Division (“NSD”) and a USAO.*
  • Defended managing director of investment adviser in resolving SEC enforcement investigation into undisclosed conflicts of interest; obtained complete dismissal with prejudice of parallel private civil securities fraud lawsuit.*
  • Represented broker-dealer in SEC investigation and settlement regarding compliance with short selling requirements (Reg SHO).*

*List includes matters completed prior to joining Crowell & Moring LLP

Sanctions and BSA/AML Regulatory & Compliance

  • Advising major European bank daily on sanctions compliance and regulatory questions, including interactions with OFAC, voluntary self-disclosures to OFAC, and responding to OFAC enforcement subpoena.
  • Advising major publicly-traded fashion company on economic sanctions, anti-corruption/FCPA, Form 8300, and other compliance matters.
  • Advising cash management solutions provider on money transmission and compliance practices in connection with services provided to Bitcoin ATM operators; advising on related seizure and forfeiture matters.
  • Advised leading U.S. financial institution on AML, SAR, and sanctions related compliance matters, including drafting SAR investigations and procedures manual.
  • Advised leading technology company all aspects of sanctions compliance including issues relating to Iran, Russia, Cuba, and North Korea; conducted due diligence of counterparties and customers relating to sanctions compliance in connection with use of client’s products and services.
  • Assisted major U.S. bank with investigation into potential customer transactions involving Cuba and advised on submission of voluntary self-disclosure (“VSD”) to OFAC.
  • Advising major financial information services provider on various U.S. sanctions-related questions and responses to OFAC.
  • Advising major health insurance provider in connection with VSD to OFAC.
  • Advised, pro bono, non-governmental organization on U.S. sanctions risks in connection with its legal representation of detained individual in claims brought before the European Court of Human Rights.

Anand's Insights

Client Alert | 4 min read | 12.19.24

DOJ Appeals Nationwide Preliminary Injunction of the Corporate Transparency Act, Seeks Stay of Injunction During its Appeal

As we discussed in our recent client alert, the U.S. District Court for the Eastern District of Texas issued an opinion and order on December 3, 2024, ("the Order") enjoining the federal government from enforcing the CTA and a rule implementing it. The rule requires certain entities formed or registered to do business in the U.S. ("reporting companies") to report information about themselves and their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury....

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Insights

Client Alert | 4 min read | 12.19.24

DOJ Appeals Nationwide Preliminary Injunction of the Corporate Transparency Act, Seeks Stay of Injunction During its Appeal

Firm News | 3 min read | 12.05.24

Crowell & Moring Notches Tenth Straight Year on “GIR 100”

Client Alert | 4 min read | 12.05.24

Federal District Court Issues Nationwide Preliminary Injunction Enjoining Enforcement of the Corporate Transparency Act

Client Alert | 9 min read | 12.03.24

The Month in International Trade – November 2024
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Practices

Industries

Anand's Insights

Client Alert | 4 min read | 12.19.24

DOJ Appeals Nationwide Preliminary Injunction of the Corporate Transparency Act, Seeks Stay of Injunction During its Appeal

As we discussed in our recent client alert, the U.S. District Court for the Eastern District of Texas issued an opinion and order on December 3, 2024, ("the Order") enjoining the federal government from enforcing the CTA and a rule implementing it. The rule requires certain entities formed or registered to do business in the U.S. ("reporting companies") to report information about themselves and their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury....

View All Insights