Government Experience

  • U.S. Department of Treasury—Attorney Advisor, Office of the General Counsel, Office of Foreign Assets Control (2001-2005); Office of International Programs, Office of Foreign Assets Control (1999-2001)

Education

  • American University Washington College of Law, J.D.
  • American University, M.A. School of International Service
  • Amherst College, B.A., cum laude

Admissions

  • District of Columbia
  • Maryland
Cari N. Stinebower, Partner Washington, D.C.
cstinebower@crowell.com
Phone: +1 202.624.2757
1001 Pennsylvania Avenue NW
Washington,, DC 20004-2595

Cari N. Stinebower is a member of Crowell & Moring's International Trade Group in the firm's Washington, D.C. office. She also works closely with colleagues in the White Collar & Regulatory Enforcement, Financial Services, Corporate and Insurance and Reinsurance groups.

Cari counsels clients on compliance with 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. She works with financial institutions and multi-national corporations to develop compliance programs, conduct AML and Office of Foreign Assets Control (OFAC) risk assessments, conduct internal investigations, respond to government investigations, and address potential conflicts of law arising from non-U.S. data privacy and "blocking" laws and regulations. Cari also works with industry groups to develop sanctions and AML best practices policies and procedures.

Cari served as counsel for the U.S. Department of the Treasury's OFAC and as a Programs Officer for OFAC, where she advised on sanctions and anti-terrorism legislation, drafted United Nations Security Council Resolutions and related executive orders. Cari acted as agency counsel in Treasury's defense of a number of challenges to OFAC's authority, whether in litigation related to enforcement actions or in response to congressional investigations. As a result of her work at Treasury, Cari received the Secretary of the Treasury's Certificate for her role in providing guidance in the war against terrorism, establishing a program targeting the Taliban, working with the interagency group to unwind the first sanctions targeting the government of Libya, and drafting the Foreign Narcotics Kingpin Designation Act.

Cari is a frequent writer and speaker on sanctions, AML and anti-corruption/anti-bribery related issues and has been quoted in publications such as the Wall Street Journal, the New Yorker, Reuters, Bloomberg and MoneyLaundering.com.

She is a member of the American Bar Association's Gatekeepers' Task Force and a vice-chair of the ABA's Anti-Money Laundering subcommittee. Cari has been a guest lecturer at the George Mason School of Law.

Cari received her B.A. from Amherst College (1993), J.D. from American University's Washington College of Law (1996) and masters from American University (1996).



Affiliations

Admitted to practice: District of Columbia, Maryland

Memberships

  • American Bar Association (ABA), Section of Administrative Law
  • Vice-Chair, Section of International Law, International Anti-Money Laundering and Professional Ethics Committee (2008 - Present)
  • ABA Gatekeepers Task Force
  • Republican National Lawyers Association (RNLA)


Speeches & Presentations

  • "Cuba: An Update on the Liberalization of Trade Relations," Crowell & Moring Seminar, New York, NY (June 18, 2015). Presenters: Cari N. Stinebower, Daniel Cannistra, Mike Gill, and Mariana Pendás Fernandez.
  • "Foreign Bank Accounts and 'Black Money' - Recent Legal Developments in the U.S. and India on Foreign Account Tax Compliance (FACTA), Corruption, and Off-Shore Accounts," U.S.-India Business Council - Discussion with Members of the Indian National Bar Association, Washington, D.C. (June 16, 2015). Panelist: Cari N. Stinebower.
  • "Cuba: An Update on the Liberalization of Trade Relations," Crowell & Moring Seminar, Washington, D.C. (April 21, 2015). Presenters: Cari N. Stinebower, Scott L. Winkelman, Daniel Cannistra, and Mariana Pendás Fernandez.
  • "This Year in Trade - What's Ahead in 2015: Sanctions," Crowell & Moring Webinar (February 10, 2015). Presenters: Dr. Salomé Cisnal de Ugarte and Cari N. Stinebower.
  • "This Year in Trade - What's Ahead in 2015: Anti-money Laundering (AML)," Crowell & Moring Webinar (February 10, 2015). Presenters: Cari N. Stinebower and Emmanuel Plasschaert.
  • Co-Chairs' Opening Remarks, ACI's 5th Annual Economic Sanctions Boot Camp, New York, NY (December 3-4, 2014). Co-Host: Cari N. Stinebower.
  • "Developing and Implementing Best Practices," ACI's Anti-Money Laundering and OFAC Compliance for Insurance Industry (January 21-22, 2014). Presenter: Cari N. Stinebower.
  • "How to Define and Prevent Facilitation: Lessons Learned from Recent OFAC Enforcement Cases and Advisory Opinions," ACI's Economic Sanctions Boot Camp (December 4-5, 2013). Presenter: Cari N. Stinebower.
  • "Crowell and Moring Breakfast Series for Foreign Financial Institutions," New York, NY (September 2013). Presenter: Cari N. Stinebower.
  • "Bank Secrecy Act and Anti-Money Launder Overview: A Primer for Transaction Counsel or 'Am I Really Supposed to Know This?'" ABA Business Law Section Spring Meeting (April 4, 2013). Presenters: Cari N. Stinebower and Scott Lessne.
  • "The Legal and Economic Impacts of Financial Sanctions on Targeted Activities and Affected Institutions," Georgetown Journal of International Law Symposium, Washington, D.C. (February 13, 2013). Moderator: Cari N. Stinebower.
  • "Benefiting From Convergence: Streamlining Your AML, Fraud Prevention, OFAC, and FCPA Programs and Leveraging Existing Resources to Increase Efficiency and Reduce Costs," ACI's AML and OFAC Compliance for the Insurance Industry (January 22-23, 2013). Presenter: Cari N. Stinebower.
  • "Developing and Implementing an AML Training Program That Will Promote Compliance at All Levels of Your Organization," Post-Conference Master Class, ACI's AML and OFAC Compliance for the Insurance Industry (January 22-23, 2013). Presenter: Cari N. Stinebower.
  • "ACFA Bank Secrecy Act and Anti-Money Launder Overview," New York, NY (January 9, 2013). Panelist: Cari N. Stinebower.
  • "Doing Business in Burma/Mynamar: What You Can and Cannot Do Under New, Eased Sanctions Restrictions," ACI OFAC Boot Camp, New York, NY (December 5-6, 2012). Panelist: Cari N. Stinebower.
  • "OFAC Facilitation: Know It When You See It?" ABA Section of International Law, Washington, D.C. (November 8, 2012). Panelist: Cari N. Stinebower.
  • "Iran, Israel and the Nuclear Issue - Key National Security Issues 2013," Georgetown Law, Washington, D.C. (October 25, 2012). Panelist: Cari N. Stinebower.
  • "Ethics in Evolving Compliance Requirements 2012," CT Corporation's 2012 Webinar Series (August 8, 2012). Speaker: Cari N. Stinebower.
  • "Streamlining Your AML, OFAC, FCPA, Programs: Leveraging Existing Resources to Increase Efficiency and Reduce Costs While Ensuring Compliance," American Conference Institute's 2nd Annual Forum, New York, NY (January 25, 2012). Co-Speaker: Cari N. Stinebower.
  • "The OFAC Licensing Process, Timeline and Criteria: How to Work with OFAC to Expedite Approvals," ACI's OFAC Bootcamp (December 2, 2011). Speaker: Cari N. Stinebower.
  • "OFAC Enforcement Trends: Lessons Learned & the Road Ahead," West Professional Development Webinar (November 29, 2011). Speaker: Cari N. Stinebower.
  • "Anti-Money Laundering, Terrorist Financing and Sanctions Compliance - Voluntary Good Practices for the U.S. Lawyer," National College of Probate Judges Fall 2011 Conference, GA (November 3, 2011). Speaker: Cari N. Stinebower.
  • "Promoting New Sudan Accountability and Reinvestment Act for 2011," The National Policy Alliance 2011 Leadership Meeting (September 20, 2011). Speaker: Cari N. Stinebower.
  • "OFAC Compliance: Legal and Ethical Responsibilities," CT Corporation 2011 Seminar Series (August 17, 2011). Speaker: Cari N. Stinebower.
  • "ACI's National Forum on AML and OFAC Compliance for the Insurance Industry," (January 20-21, 2011). Co-Chair: Cari N. Stinebower.
  • "Sanctions: Developing and Implementing Policies and Procedures to Ensure Compliance with State and Federal Mandates," ACI's National Forum on AML and OFAC Compliance for the Insurance Industry (January 20, 2011). Speaker: Cari N. Stinebower.
  • The Cost of Non-Compliance: What Recent Cases and Penalty Levels Reveal About OFAC's Priorities and Enforcement Approach," ACI's OFAC Boot Camp (December 9, 2010). Speaker: Cari N. Stinebower.
  • "The Foreign Corrupt Practices Act and Anti-Money Laundering," ILI's Orientation in the U.S. Legal System (July 28, 2010). Speaker: Cari N. Stinebower.
  • "Evolving Compliance Requirements and Ethical Considerations for the Business Law Attorney," CT Corporation's 2010 Seminar Series (June 17, 2010). Speaker: Cari N. Stinebower.
  • "Complying with Tightened International Sanctions against Iran: What You Can Do and What You Can't Do," ACI OFAC Enforcement & Compliance (April 29-30, 2010). Panelist: Cari N. Stinebower.
  • "Report and Recommendation on Voluntary Guidance on AML for Lawyers," The ABA's Section of International Law Council Meeting (April 17, 2010). Speaker: Cari N. Stinebower.
  • "Preventing Federal Intrusion into State Supreme Court Regulation of Lawyers," ABA Midyear Meeting 2010 (February 4, 2010). Panelist: Cari N. Stinebower.
  • "Foreign Corrupt Practices Act: How New Enforcement Will Impact Your Business," Foreign Corrupt Practices Act Webinar (January 26, 2010). Speaker: Cari N. Stinebower.
  • "Tailoring Your AML Program to Comply with the Foreign Corrupt Practices Act," Association of Certified Anti-Money Laundering Specialists Webinar (November 18, 2009). Speaker: Cari N. Stinebower.
  • "Due Diligence in Government Contractor Mergers and Acquisitions," Federal Publications Seminars (October 28-29, 2009). Speaker: Cari N. Stinebower.
  • "Corporate Transparency and Other International Issues," 21st Annual ABA Money Laundering Enforcement Conference (October 11, 2009). Speaker: Cari N. Stinebower.
  • "How Well Do You Know Your Client?," 2009 CTLA Annual Conference (October 1-3, 2009). Speaker: Cari N. Stinebower.
  • "Terrorism and the Corporation: Ethical Implications for Officers, Directors and Their Counsel," Seattle University School of Law: The Annual James L. Holman Ethics Program (April 3, 2009). Speaker: Cari N. Stinebower.
  • "U.S. Embargoes and Economic Sanctions Law: Recent Developments Involving Iran, Cuba, Sudan and “Specially Designated Nationals"," 2008 ABA Annual Meeting (August 10, 2008). Speaker: Cari N. Stinebower.


Publications



Client Alerts & Newsletters



In the News

  • Private Bank Fuels Fortunes of Putin's Inner Circle
    September 27, 2014 — New York Times

    Washington, D.C.-based International Trade Group partner, Cari N. Stinebower, is quoted in New York Times cover story that offers in depth analysis on the workings of Russian President Vladimir Putin's inner circle and their financial transactions. In particular, the article notes that Bank Rossiya, an entity subject to U.S. sanctions, was created for what the Obama administrations calls the "personal bank" of the Putin inner circle. The article notes that this bank, like many others, is webbed into a shell of companies – but that the ownership structure for these companies is not readily identifiable. The lack of transparency into ownership structure says Stinebower, who advises clients on compliance with sanctions, raises "red flags" and corresponding enhanced due diligence requirements. Treasury has clarified that any entity 50 percent or more owned by a sanctioned person is also blocked by operation of law. With regard to CTC Media (CTC), a company with several television channels that was partially owned by a subsidiary of Bank Rossiya, Video International and an agreement CTC had with the subsidiary, Stinebower comments, "The way the law works, it's incumbent on CTC to understand the beneficial ownership of the company they are doing business with" to ensure that there is not "some sanctioned entity at the end of the chain." It has been reported that Video International was able to maneuver around Russian law and placed CTC at risk for violating American sanctions.


  • DC Focus: The City. The Law. The Lawyers.
    May 2014, Issue 31 — World ECR

    Crowell & Moring LLP's International Trade Group was featured in a WorldECR special report examining the importance of Washington, D.C. in the U.S. and international export controls and sanctions landscape. The report talked with Crowell & Moring attorneys and other leading lawyers about the impact of U.S. Export Control Reform on real-life business, U.S. sanctions policy and practice, and other issues. WorldECR is the journal of export controls and sanctions.


  • FCPA Powerhouse: Crowell & Moring
    May 29, 2013 — Law360

    Crowell & Moring's White Collar & Regulatory Enforcement Group has been named as one of Law360's 10 "FCPA Powerhouses" for its prowess handling Foreign Corrupt Practice Act (FCPA) matters. The Law360 editors noted, "With Foreign Corrupt Practices Act experience tracing back to the firm's founding in the late 1970s, Crowell & Moring LLP has continued to make its mark in the arena, recently guiding Ralph Lauren Corp. and a Lindsey Manufacturing Co. Executive to successful outcomes in FCPA cases." The factors considered in selecting the winners included the number of attorneys at the firm working on FCPA matters and contributions to this developing area of law, including working on landmark FCPA cases, as well as client representations and outcomes.


  • Expected Guidance on 'Simplified' Diligence Likely to Closely Follow FATF's Lead
    March 28, 2012 — MoneyLaundering.com

    Washington, D.C.-based International Trade Group counsel Cari N. Stinebower speaks to MoneyLaundering.com about the guidance expected from the U.S. Treasury Department on how to ease compliance controls on certain low-risk accounts and products. The U.S. Treasury department is expected to take its queue from the Paris-based Financial Action Task Force's (FATF) call for jurisdictions to implement "simplified" customer due diligence procedures, which would allow financial institutions to relax the anti-money laundering controls commensurate with the lower risk of certain accounts and financial products.

    According to the article, Stinebower said "The department is unlikely to veer from FATF's guidelines on simplified measures. U.S. officials could say that less due diligence is needed for accounts held for federal agencies, certain closed-loop prepaid products and small businesses that don't rely heavily on cash or have international ties."


  • US Companies Lose as Sanctions Strangle Iran
    March 20, 2012 — Reuters

    Washington, D.C.-based International Trade Group counsel Cari N. Stinebower speaks to Reuters about how difficult it is for U.S. firms, large and small alike, to receive payment for products that they sold to Iran, even for medicines and other humanitarian exports explicitly allowed by the U.S. Treasury.

    According to the article, Stinebower said, "Everything from aspirin to multivitamins - you name it - it's all jammed up."

  • Global Insurers Targeted in Proposed Sanctions Against Iran
    March 8, 2012 — Bloomberg News

    Washington, D.C.-based International Trade Group counsel Cari N. Stinebower speaks to Bloomberg News about U.S. lawmakers' efforts to target global insurers as they seek to expand sanctions aimed at crippling Iran's economy and forcing its leaders to make concessions involving the country's disputed nuclear program.

    According to the article, Stinebower said "U.S. insurers tend to be very careful about compliance."



Firm News & Announcements

Jan.13.2015 Crowell & Moring Releases Third Annual Litigation Forecast Report and Inaugural Regulatory Forecast
Sep.30.2014 Super Lawyers 2014 Recognizes 90 Crowell & Moring Attorneys
May.27.2014 Crowell & Moring's Insurance/Reinsurance Group Nominated for Chambers USA "Award of Excellence"
Jan.14.2014 Crowell & Moring Elects Five New Partners and Promotes Fourteen Associates to Counsel
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