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Carlton Greene

Phone: +1 202.624.2818
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Carlton Greene is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm's International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Before joining FinCEN, Carlton previously served as the assistant director for transnational threats with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), where he directed targeting and investigations for more than 15 U.S. economic sanction programs, including those related to Iran and North Korea. Carlton also served as legal counsel to OFAC on counterterrorism sanctions. Previously, he was appointed by the United Nations Secretary-General to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. Carlton also previously served as a trial attorney at the U.S. Department of Justice, where his practice included representing OFAC on sanctions issues.

Based on his years of experience with OFAC and FinCEN, Carlton offers valuable insights on the approaches of these agencies that will assist corporate clients to more effectively respond to government investigations, as well as update their corporate compliance programs in general.


  • College of William & Mary, B.A. philosophy (1993)
  • College of William & Mary Marshall-Wythe School of Law, J.D. (1997)


Admitted to practice: District of Columbia, Virginia

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"OFAC Limits Cuba “U-Turn” Payments and Remittances," International Trade Bulletin (September 13, 2019). Contacts: David (Dj) Wolff, Carlton Greene, Nicole Sayegh Succar
Client Alert/Newsletter
"The Month in International Trade – August 2019," International Trade Bulletin (September 6, 2019). Contacts: Jeffrey L. Snyder, Daniel Cannistra, John B. Brew, David (Dj) Wolff, Maria Alejandra (Jana) del-Cerro, Edward Goetz, Frances P. Hadfield, Aaron Marx, Carlton Greene, Ru Xiao-Graham, Robert L. LaFrankie, Robert Holleyman, Cherie Walterman, Erik Woodhouse, Spencer Toubia, Nicole Sayegh Succar, Walter (Sam) Boone
Client Alert/Newsletter
"FinCEN Announces New Global Investigations Division and New Leader for Liaison Division," International Trade Bulletin (September 5, 2019). Contacts: Carlton Greene, Rebecca Monck Ricigliano, Nicole Sayegh Succar
Client Alert/Newsletter
Humanitarian Groups Face Banking Challenges As Venezuelan Sanctions Escalate Wall Street Journal (August 16, 2019)
In the News
"United States Ramps Up Sanctions Pressure on Russia and Venezuela," International Trade Bulletin (August 13, 2019). Contacts: Erik Woodhouse, David (Dj) Wolff, Carlton Greene, Nicole Sayegh Succar, Maria Alejandra (Jana) del-Cerro
Client Alert/Newsletter
"Recent EU Money Laundering Scandals Lead EU to Call for Stricter Implementation of the Anti-Money Laundering Rules by Member States," White Collar Alert (August 8, 2019). Contacts: Carlton Greene, Danielle Giffuni, Michelle J. Linderman, Laurence Winston
Client Alert/Newsletter
Russia Sanctions Froze His Fortune. Can the 4th Amendment Unlock it? The New York Times (July 1, 2019)
In the News
Chinese Woman’s Secret Arrest Hints at Wider Probe Bloomberg (May 12, 2019)
In the News
"The Month in International Trade – March 2019," International Trade Bulletin (April 12, 2019). Contacts: Jeffrey L. Snyder, Frances P. Hadfield, Edward Goetz, Carlton Greene, David (Dj) Wolff, John L. Murino, David Baron, David B. Robbins, Emily Alban
Client Alert/Newsletter
"OFAC Begins to Solidify Long-Awaited Guidance on Expected Elements for OFAC Compliance Programs," International Trade Bulletin (April 8, 2019). Contacts: David (Dj) Wolff, Carlton Greene
Client Alert/Newsletter

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Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, and Brussels.

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