Photograph of Caroline E. Brown

Caroline E. Brown

Partner


Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm's National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

Most recently, she served as an Attorney-Advisor in the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), where she developed an in-depth understanding of AML regulation and enforcement and FinCEN’s role in guarding the U.S. financial system against money laundering and terrorist financing. Before joining FinCEN, she served as an attorney in the Treasury Department’s Office of General Counsel, Enforcement and Intelligence, which provides counsel to the Undersecretary for Terrorism and Financial Intelligence. There, Caroline advised on sanctions, AML, and various other national security issues relevant to the nation’s financial system.

While at DOJ, Caroline was detailed to the White House for a year, where she coordinated communications strategy focused on national security. She previously worked on the 2008 Obama Presidential Campaign and served on the Obama Presidential Transition Team from 2008 to 2009. Her time at the White House as well as at Treasury and DOJ has given her significant experience managing rapid response and crisis communications.

Caroline’s time in government has enabled her to build strong relationships at senior levels across a number of U.S. government agencies, including DOJ, the FBI, the National Intelligence Council and other components of the Intelligence Community, the FCC, and the Departments of Defense, Homeland Security, State, Energy, Commerce, and the Treasury.

Caroline began her legal career as a law clerk for the Honorable Jon McCalla in the U.S. District Court for the Western District of Tennessee before joining the litigation group of a global law firm in Washington, D.C. She is a former term member on the Council on Foreign Relations, a National Security Fellow at the Foundation for the Defense of Democracies, an Aspen Institute Socrates Scholar, and a Young Leader of the transatlantic organization Atlantik-Brucke.   

Education

  • Duke University, B.A. (1998)
  • University of Michigan Law School, J.D. (2002)

Affiliations

Admitted to practice: District of Columbia, New York


Professional Activities and Memberships

  • Council on Foreign Relations, Term Member (former)
  • National Security Fellow, Foundation for the Defense of Democracies
  • Socrates Scholar, Aspen Institute
  • Atlantik-Brucke

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Practices

White Collar and Regulatory Enforcement

International Trade

Coronavirus (COVID-19) Response Team

Investigations

National Security

International Trade Investigations

Privacy and Cybersecurity

Anti-Corruption and FCPA Investigations

Anti-Money Laundering Investigations

Privacy and Cybersecurity Investigations

Financial Services

Supply Chain Management

Sanctions and Embargoed Countries

Anti-Money Laundering (AML)

Committee on Foreign Investment in the United States (CFIUS)

FinTech

Digital Assets and Payments

Regulatory and Enforcement

Blockchain and Financial Services Technology

Non-Fungible Tokens (NFTs)

Export Controls

Show more practices…

"CFIUS Formalizes Its Enforcement and Penalty Process," International Trade Bulletin (October 27, 2022). Contacts: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley, Nimrah Najeeb
Client Alert / Newsletter
"Blockchain, Crypto, Bored Apes, Oh My!" National Association of Women Lawyers Webinar, 2022. (October 4, 2022). Speakers: Caroline E. Brown.
Speech/Presentation
Biden Directs CFIUS To Focus On Cybersecurity, Supply Chain CQ Roll Call (September 19, 2022)
Press Coverage
"Biden Administration Announces Presidential Directive on Sharpening Foreign Investment Screening by CFIUS," International Trade Bulletin (September 16, 2022). Contacts: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley, Jeremy Iloulian, Nimrah Najeeb
Client Alert / Newsletter
Biden Warns Cfius On Serial Acquisitions The Deal (September 16, 2022)
Press Coverage
"Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers," International Trade Bulletin (August 17, 2022). Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Jackie Schaeffer
Client Alert / Newsletter
We Crowdsource Key Takeaways From CFIUS’ First Conference Foreign Investment Watch (July 3, 2022)
Press Coverage
"New Law Gives NYDFS Authority to Make Virtual Currency Business Activities in New York More Expensive," Privacy Law Alert (May 11, 2022). Contacts: Garylene (Gage) Javier, CIPP/US, Anand Sithian, Carlton Greene, Caroline E. Brown, Kelly T. Currie, Nicole Sayegh Succar
Client Alert / Newsletter
"Sanctions/Export Highlights [As of May 6, 2022]," Crowell & Moring’s International Trade Law Blog (May 6, 2022). Authors: Jeffrey L. Snyder, Carlton Greene, Michelle Linderman, Caroline Brown, Nicole Succar, Anand Sithian, Brian McGrath, Laurel Saito, and Rachel Schumacher.
Publication
"Russia Sanctions/Export Highlights [As of April 28, 2022]," Crowell & Moring’s International Trade Law Blog (April 28, 2022). Authors: Caroline Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Laurel Saito, and Rachel Schumacher.
Publication

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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