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Carlton Greene

Partner

cgreene@crowell.com
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.

Education

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

Affiliations

Admitted to practice: District of Columbia, Virginia (inactive)

View More

"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.
Publication
"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: Michelle Ann Gitlitz, 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.
Publication
"Agency Issues First National Priorities for Anti-Money Laundering and Counter-Terrorist Financing, Completes Assessment on Potential No-Action Letter Process, Provides 180-Day Update on AML Act Implementation, and Appoints First-Ever Chief Digital Currency Advisor," Crowell & Moring’s International Trade Law (July 15, 2021). Authors: Caroline E. Brown, Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian and Nicole Sayegh Succar.
Publication
"FinCEN Issues Major Anti-Money Laundering Act Announcements and Appoints New Chief Digital Currency Advisor," Financial Services Alert (July 14, 2021). Contacts: Caroline E. Brown, Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian, Nicole Sayegh Succar
Client Alert / Newsletter
Deutsche Bank Overhauls Anti-Financial Crime Operations Wall Street Journal (June 24, 2021)
Media Mentions
"Don’t be that Victim: The Critical Need for Ransomware Response Plans," Privacy Law Alert (June 23, 2021). Contacts: Michael K. Atkinson, Caroline E. Brown, Laura Foggan, Michelle Ann Gitlitz, Carlton Greene, Michelle J. Linderman, Jeffrey L. Poston, Paul M. Rosen, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner, Matthew B. Welling
Client Alert / Newsletter
"A Ransomware Attack Primer: What You Need to Know and What Crowell Can Do to Help," Privacy Law Alert (June 17, 2021). Contacts: Michael K. Atkinson, Caroline E. Brown, Laura Foggan, Michelle Ann Gitlitz, Carlton Greene, Michelle J. Linderman, Jeffrey L. Poston, Paul M. Rosen, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner, Matthew B. Welling
Client Alert / Newsletter
"Digital Asset Investigation and Enforcement Trends," Investigations: Readiness and Response Webinar Series (April 28, 2021). Presenters: Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, and Daniel L. Zelenko.
Speech/Presentation
"SEC Risk Alert Provides Valuable Reminders Concerning Importance of Compliance with SAR Reporting Requirements," Administrative Law Alert (April 21, 2021). Contacts: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Tiffany Wynn, Allison Skager
Client Alert / Newsletter

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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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