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Caroline E. Brown

Phone: +1 202.624.2509
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

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. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, cybersecurity, cross border data transfers, and investigations. Caroline also advises companies navigating review by the Committee on Foreign Investment in the United States (CFIUS).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. 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.

Prior to joining Treasury, Caroline was an Attorney-Advisor in the National Security Division of the U.S. Department of Justice (DOJ). In that role, Caroline made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by CFIUS and the group of U.S. government agencies known as “Team Telecom.” She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements. During her tenure at DOJ, Caroline also worked on counterterrorism, counterespionage, and cybersecurity matters and gained unique insight into issues surrounding data privacy and cybersecurity.

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, 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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"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.
President Trump's Move To Force ByteDance to Sell TikTok Is Part Of A Growing Global Trend Of Countries Scrutinizing Who Owns Their Citizens' Data Business Insider (September 17, 2020)
Media Mentions
"CFIUS Mandatory Declarations – Bye, Bye NAICS Codes; Hello "Regulatory Authorizations"," Government Contracts Bullet Points (September 15, 2020). Contacts: Alan W. H. Gourley, Maria Alejandra (Jana) del-Cerro, Adelicia R. Cliffe, Caroline E. Brown
Client Alert / Newsletter
"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
"CFIUS Review Culminates in Order Directing ByteDance, Ltd. to Divest TikTok," (August 18, 2020). Contacts: Caroline E. Brown, Robert Holleyman
Client Alert / Newsletter
"New Executive Orders Start Clock Ticking for TikTok and WeChat," International Trade Bulletin (August 11, 2020). Contacts: Caroline E. Brown, Robert Holleyman
Client Alert / Newsletter
Confusion Prevails Over Extent Of Trump's TikTok 'Ban' Law360 (August 10, 2020)
Media Mentions
"Trump's TikTok, WeChat Orders May Yield Different Results," Law360 (August 6, 2020). Authors: Caroline E. Brown, and Robert Holleyman.

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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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