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Caroline E. Brown

Phone: +1 202.624.2509
1001 Pennsylvania Avenue NW
Washington, DC 20004

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 in 2008-2009. 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.   


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


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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"Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics," International Trade Bulletin (November 15, 2021). Contacts: Caroline E. Brown, Carlton Greene, Paul M. Rosen, Sarah Bartle, Anand Sithian, Nicole Sayegh Succar
Client Alert / Newsletter
"Stablecoin Regulation Is Coming? President’s Working Group Issues Report on Stablecoins Outlining Stablecoin Risks and Requesting Congress Pass Urgent Legislation Regulating Stablecoins," Blockchain Alert (November 15, 2021). Contacts: Carlton Greene, Anand Sithian, Stephanie L. Crawford, Richard B. Holbrook Jr., Caroline E. Brown, Michel C. Narganes
Client Alert / Newsletter
Crowell & Moring Named to "GIR 100" for Seventh Consecutive Year (Nov.11.2021)
Firm News / Announcement
"Blockchain & Cryptocurrency Regulation 2022 - An Introduction To Virtual Currency Money Transmission Regulation," Global Legal Insights (November 8, 2021). Author: Carlton Greene, Caroline E. Brown, and Michelle Gitlitz.
Pandora Papers Leak Drops Amid U.S. Anti-Money Laundering Regulatory Overhaul Kharon (October 13, 2021)
Media Mentions
"OFAC Issues Updated Guidance on Ransomware Attacks and Imposes First Sanctions Designation on a Virtual Currency Exchange," International Trade Bulletin (September 28, 2021). Contacts: Caroline E. Brown, Laura Foggan, Carlton Greene, Jeffrey L. Poston, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner, Alexander Urbelis, Anand Sithian, Matthew B. Welling, Rebecca Lennon Baskin
Client Alert / Newsletter
"3rd Virtual Conference on U.S.-China Trade Controls," American Conference Institute (September 20, 2021). Speaker: Caroline Brown.
"New York Governor Kathy Hochul Announces Nomination of Adrienne Harris as Superintendent of the New York Department of Financial Services," Crowell & Moring’s International Trade Law (September 2, 2021). Authors: Caroline E. Brown, Carlton Greene, Anand Sithian, Frances P. Hadfield and Martín Yerovi.
"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register," Financial Services Alert (August 25, 2021). Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Chris Murphy
Client Alert / Newsletter
"FinCEN Issues Major Anti-Money Laundering Act Announcements And Appoints New Chief Digital Currency Advisor," Westlaw Today (July 30, 2021). Authors: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Anand Sithian.

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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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