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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 Fortress Energy: Contract With Nicaraguan Company With Strong Ties To Sanctioned Entity And Unknown Ownership Raises Red Flags, Potentially Exposing New Fortress To Legal Risk, Experts Say The Capitol Forum (October 19, 2020)
Media Mentions
Why Arthur Hayes Is Facing 5 Years In Prison / BitMEX Charges Explained (video clip) Cointelegraph (October 14, 2020)
Media Mentions
"OFAC and FinCEN Release Advisories on Risks of Ransomware Payments," International Trade Bulletin (October 8, 2020). Contacts: Caroline E. Brown, Carlton Greene, Paul M. Rosen, David (Dj) Wolff, Evan D. Wolff, Erik Woodhouse
Client Alert / Newsletter
"FinCEN Issues Final Rule Establishing Anti-Money Laundering Requirements for State-Regulated Banks," International Trade Bulletin (September 28, 2020). Contacts: Carlton Greene, Caroline E. Brown, Michelle Ann Gitlitz, Nicole Sayegh Succar, Erik Woodhouse
Client Alert / Newsletter
"FinCEN Issues ANPRM Seeking Comment on Requirement for an "Effective and Reasonably Designed" AML Program," International Trade Bulletin (September 24, 2020). Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Erik Woodhouse
Client Alert / Newsletter
"Managing An AML Program During COVID-19," ABA Banking Journal: Risk & Compliance (September 17, 2020). Authors: Caroline E. Brown, Carlton Greene, and Erik Woodhouse.
Publication
"FinCEN Issues New Guidance for Complying with the CDD Rule," International Trade Bulletin (August 18, 2020). Contacts: Erik Woodhouse, Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
Client Alert / Newsletter
"Recent FinCEN Advisories on Medical and Consumer Fraud Scams Related to the COVID-19 Pandemic," Crowell & Moring’s International Trade Law (July 29, 2020). Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar and Alex Rosen.
Publication
"FinCEN Issues Alert to Financial Institutions Regarding Scam Involving Twitter," Crowell & Moring’s International Trade Law (July 22, 2020). Authors: Carlton Greene, Caroline E. Brown, Erik Woodhouse, Michelle Ann Gitlitz and Justin Porter.
Publication
"Creation of a New Hong Kong-Related Sanctions Program," (July 17, 2020). Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar, Erik Woodhouse
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, Brussels, and Shanghai.

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