Insights

Washington – June 24, 2024: Crowell & Moring has been recommended in eight practice areas in the 17th edition of the Legal 500 United States. In addition, partner Daniel Forman, co-chair of the firm’s Government Contracts Group, has been named to the Legal 500’s “Hall of Fame” for Government Contracts.

Since December of last year, the status of the CTA has been in a state of perpetual flux, following a dizzying series of federal court rulings and FinCEN announcements. On February 28, 2025, we reported that FinCEN paused enforcement actions for entities required to report under the CTA’s Beneficial Ownership Information Reporting Rule (BOI Rule) until FinCEN issued an interim final rule providing new guidance regarding the BOI Rule’s requirements and associated deadlines. Then, on March 2, 2025, Treasury went a step further, indicating that it would altogether cease enforcement against U.S. citizens and domestic reporting companies for violations of the BOI Rule, explaining that it would instead issue proposed rulemaking to narrow the scope of the BOI Rule to “foreign reporting companies” only and set new reporting deadlines. 

As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary instead. The EU package was more fulsome than the UK package, including new port and airport restrictions, additional trade restrictions (including an aluminium ban), enhanced military end-user restrictions, and additional asset freezes and vessel designations.

On February 28, 2025, we reported that the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) paused enforcement actions for entities required to report under the CTA’s BOI Rule (Reporting Companies) for failure to file or update beneficial ownership information (BOI) reports by a previously-announced March 21, 2025, deadline. FinCEN had explained that the pause would last until it issued an interim final rule further updating reporting deadlines and providing new guidance around the BOI Rule’s requirements.

On October 12-13, Crowell is proud to sponsor ACI's first Forum on Digital Assets Compliance: AML, Sanctions & Fraud. Carlton Greene, chair of Crowell's Financial Services practice, will be moderating an in-house executive roundtable discussing Perspectives on Managing the Latest Emerging Opportunities and Risks Confronting the Crypto Industry. Key discussion areas for the panel will include:

On January 7, 2020, the OCIE of the Securities and Exchange Commission, responsible for overseeing investment advisers, broker-dealers and others, announced its 2020 examination priorities. We will review these priorities, with special attention paid to financial technology and innovation, including digital assets and anti-money laundering (AML) programs.

Carlton Greene will be speaking on a panel. The topic: "AML/Sanctions Regulation and Enforcement Update." This panel reviews recent developments and changes in the anti-money laundering and sanctions compliance landscape.

Thursday, October 10, 2024Understanding FinCEN's Final Rule: AML/CFT Compliance for Investment AdvisersClick here to view the on-demand webinar program.On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that will impose new anti-money laundering and countering the financing of terrorism (AML/CFT) requirements on SEC-registered investment advisers and exempt reporting advisers. Join us for an insightful webinar on the new regulatory requirements issued by FinCEN. This session will provide a comprehensive overview of the specific requirements for AML/CFT compliance programs, as well as key takeaways and issues to keep top of mind as we move into this new enforcement era.

Please join us for a discussion to explore key issues in the business community as the war in Ukraine continues to reverberate through the global supply chain.

Crowell & Moring’s sanctions team provides guidance on the rapidly-changing U.S. sanctions against Russia, including measures against various Russian banks and Russia’s central bank, National Wealth Fund, and Ministry of Finance, and how these new sanctions can arise in syndicated loans and other lending arrangements, and loan trading.

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law and public policy as they impact our lives. In this podcast, hosts Nicole Simonian and Ambassador Robert Holleyman talk to Crowell & Moring Partners Dj Wolff and Carlton Greene, who both specialize in economic sanctions, about the U.S. and global economic response to the Russia-Ukraine conflict and the impact on global supply chain. Specifically, they will discuss what listeners should be looking out for, and help them expect the unexpected.