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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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"U.S. Government Issues First Designations under the Caesar Act as Part of Larger Set of Designations Targeting the Syrian Government," International Trade Bulletin (June 25, 2020). Contacts: Caroline E. Brown, Carlton Greene, Erik Woodhouse, David (Dj) Wolff, Nicole Sayegh Succar, Tyler Brown
Client Alert / Newsletter
"Key Lessons Learned as UK’s AML Regulator Shows its Teeth," International Trade Bulletin (June 23, 2020). Contacts: Michelle J. Linderman, Nicola Phillips, Carlton Greene, Erik Woodhouse
Client Alert / Newsletter
"Sanctions Order May Accelerate Decline In US-ICC Relations," Law360 (June 22, 2020). Authors: Caroline E. Brown, Erik Woodhouse, Brian McGrath, Carlton Greene, David Wolff, and Nicole Sayegh Succar.
"President Issues Executive Order Authorizing Sanctions on Certain Persons Associated with the International Criminal Court," International Trade Bulletin (June 17, 2020). Contacts: Caroline E. Brown, Erik Woodhouse, Brian McGrath, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
Client Alert / Newsletter
"Revisions to DOJ’s Corporate Compliance Guidance Indicate that a Dynamic, Data-Driven and Well-Resourced Compliance Program is More Important than Ever," White Collar Alert (June 8, 2020). Contacts: Jacinta Alves, Lorraine M. Campos, Carlton Greene, Derek A. Hahn, Thomas A. Hanusik, Gail D. Zirkelbach, Paul Freeman, Tiffany Wynn
Client Alert / Newsletter
"FinCEN’s Suspicious Activity Report Renewal Notice Seeks Public Comment on SAR Burden Estimates," International Trade Bulletin (June 1, 2020). Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Erik Woodhouse
Client Alert / Newsletter
"FinCEN Director Identifies Virtual Currency Compliance Risks and COVID-19 Related Issues at Consensus 2020 Conference," White Collar Alert (May 20, 2020). Contacts: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Jorge Pesok, Nicole Sayegh Succar, Erik Woodhouse
Client Alert / Newsletter
"Key Lessons Learned as OFSI Begins to Flex its Muscles," International Trade Bulletin (May 19, 2020). Contacts: Michelle J. Linderman, David (Dj) Wolff, Caroline E. Brown, Carlton Greene
Client Alert / Newsletter
"Emerging Issues in Sanctions, AML and Everything in Between in the Time of COVID-19: 2020 AML & Sanctions Risk Considerations for Digital Assets Companies," Crowell & Moring Webinar (May 19, 2020). Presenters: Caroline E. Brown, Michelle Gitlitz, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Nicole Sayegh Succar, and Erik Woodhouse.
"New U.S. Sanctions Advisory for the Maritime Industry," International Trade Bulletin (May 15, 2020). Contacts: David (Dj) Wolff, Michelle J. Linderman, Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Nimrah Najeeb
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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