Caroline E. Brown
Overview
Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar and Regulatory Enforcement and International Trade groups and the steering committee of the firm's National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).
Career & Education
- Department of the Treasury
 Attorney-Advisor, Office of the General Counsel, Enforcement and Intelligence, 2015–2019
 Attorney-Advisor, Financial Crimes Enforcement Network, 2009–2014
- The White House
 Detailed from DOJ to the White House Office of Communications, 2010–2011
- Department of Justice: National Security Division
 Attorney-Advisor, 2009–2015
 
- Department of the Treasury
- University of Michigan Law School, J.D., 2002
- Duke University, B.A., 1998
 
- District of Columbia
- New York
 
- Law Clerk to the Hon. Jon P. McCalla, U.S. District Court for the Western District of Tennessee, 2002–2003
 
- Professional Activities and Memberships- Council on Foreign Relations, Life Member
- National Security Fellow, Foundation for the Defense of Democracies
- Socrates Scholar, Aspen Institute
- Atlantik-Brucke
 
Caroline's Insights
Press Coverage | 09.23.25
What To Do If Your Company Discovers A North Korean Worker In Its Ranks
- Client Alert | 9 min read | 09.22.25 - From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes 
- Client Alert | 6 min read | 08.12.25 - Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case 
- Client Alert | 4 min read | 08.06.25 - FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers 
Recognition
- Foreign Investment Watch: Top Advisor, 2024, 2025
Caroline's Insights
Press Coverage | 09.23.25
What To Do If Your Company Discovers A North Korean Worker In Its Ranks
- Client Alert | 9 min read | 09.22.25 - From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes 
- Client Alert | 6 min read | 08.12.25 - Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case 
- Client Alert | 4 min read | 08.06.25 - FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers 
Insights
- |07.11.23 The Banking Law Journal 
- |11.08.21 Global Legal Insights 
 
- NAFA Transactional Integrity Webinar: Navigating Russian Sanctions |- 06.05.24 
- Red Flags: Navigating the Hurricane (2024 Corporate Counsel Section CLE) |- 02.02.24 
 
- CFIUS “Black Box” Likely To Remain, Despite New Enforcement Updates |- 08.23.24 - Global Competition Review 
- Czech Arms Company Reassures CFIUS Over Purchase Of US Ammunition Business |- 04.09.24 - Global Competition Review 
- President Biden Issues Executive Order On Sensitive Personal Data |- 03.01.24 - Foreign Investment Watch 
- Treasury Already Seeking Comments On The Outbound Investment Regime |- 08.14.23 - Foreign Investment Watch 
 
- |07.07.25 Crowell & Moring’s International Trade Law 
- U.S. Department of the Treasury to Establish Fast Track CFIUS Process for Foreign Investors |- 05.09.25 - Crowell & Moring’s International Trade Law 
- OFAC Publishes Guidance on Extended Statute of Limitations |- 07.26.24 - Crowell & Moring’s International Trade Law 
- |09.01.23 Crowell & Moring’s Crypto Digest 
- Sanctions/Export Highlights [As of May 6, 2022] |- 05.06.22 - Crowell & Moring’s International Trade Law 
- Russia Sanctions/Export Highlights [As of April 28, 2022] |- 04.28.22 - Crowell & Moring’s International Trade Law 
- Sanctions/Export Highlights [As of April 7, 2022] |- 04.08.22 - Crowell & Moring’s International Trade Law 
- |09.02.21 Crowell & Moring’s International Trade Law 
- |07.16.21 Crowell & Moring’s International Trade Law 
- |07.15.21 Crowell & Moring’s International Trade Law 
 
Caroline's Insights
Press Coverage | 09.23.25
What To Do If Your Company Discovers A North Korean Worker In Its Ranks
- Client Alert | 9 min read | 09.22.25 - From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes 
- Client Alert | 6 min read | 08.12.25 - Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case 
- Client Alert | 4 min read | 08.06.25 - FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers 




