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
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
U.S. Government and private sector sources continue to report efforts by Democratic People’s Republic of Korea (DPRK) nationals to infiltrate companies around the world by posing as information technology (IT) professionals, in order to get hired by U.S. and other businesses and gain access to sensitive company systems. Crowdstrike, a U.S. cybersecurity company, has reported a 220% increase in the number of companies infiltrated by North Korean threat actors over the last 12 months. In particular, a DPRK-affiliated group known as “Famous Chollima” has leveraged artificial intelligence and deepfake technology to generate synthetic identities, as well as resumes and CVs, draft communications, and conduct job interviews. Enforcement actions brought by the U.S. Department of Justice identify victims in the cryptocurrency sector, including decentralized finance (“DeFi”) projects. In addition, media reports indicate that North Korean hackers are purportedly offering fake job offers targeting employees in the cryptocurrency sector, with the goal of stealing crypto.
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
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
U.S. Government and private sector sources continue to report efforts by Democratic People’s Republic of Korea (DPRK) nationals to infiltrate companies around the world by posing as information technology (IT) professionals, in order to get hired by U.S. and other businesses and gain access to sensitive company systems. Crowdstrike, a U.S. cybersecurity company, has reported a 220% increase in the number of companies infiltrated by North Korean threat actors over the last 12 months. In particular, a DPRK-affiliated group known as “Famous Chollima” has leveraged artificial intelligence and deepfake technology to generate synthetic identities, as well as resumes and CVs, draft communications, and conduct job interviews. Enforcement actions brought by the U.S. Department of Justice identify victims in the cryptocurrency sector, including decentralized finance (“DeFi”) projects. In addition, media reports indicate that North Korean hackers are purportedly offering fake job offers targeting employees in the cryptocurrency sector, with the goal of stealing crypto.
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
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
|09.22.25
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
Latest DOJ, Treasury, Commerce Guidance Implies More Than It Updates
|07.28.23
Global Investigations Review
- |
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
Client Alert | 9 min read | 09.22.25
From Deepfakes to Sanctions Violations: The Rise of North Korean Remote IT Worker Schemes
U.S. Government and private sector sources continue to report efforts by Democratic People’s Republic of Korea (DPRK) nationals to infiltrate companies around the world by posing as information technology (IT) professionals, in order to get hired by U.S. and other businesses and gain access to sensitive company systems. Crowdstrike, a U.S. cybersecurity company, has reported a 220% increase in the number of companies infiltrated by North Korean threat actors over the last 12 months. In particular, a DPRK-affiliated group known as “Famous Chollima” has leveraged artificial intelligence and deepfake technology to generate synthetic identities, as well as resumes and CVs, draft communications, and conduct job interviews. Enforcement actions brought by the U.S. Department of Justice identify victims in the cryptocurrency sector, including decentralized finance (“DeFi”) projects. In addition, media reports indicate that North Korean hackers are purportedly offering fake job offers targeting employees in the cryptocurrency sector, with the goal of stealing crypto.
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