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Carlton Greene

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Partner
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Areas of Focus

Overview

Clients look to Carlton for in-depth knowledge and practical, innovative solutions on sensitive economic sanctions and anti-money laundering (“AML”) matters, informed by his many years in government at the Office of Foreign Assets Control (“OFAC”), Financial Crimes Enforcement Network (“FinCEN”), and the Department of Justice (“DOJ”). Carlton Greene is the co-chair of the firm’s financial services group, and a member of its international trade and white collar and regulatory enforcement groups.

Carlton is the former chief counsel at FinCEN, the U.S. AML regulator responsible for administering the Bank Secrecy Act. Before joining FinCEN, he was an attorney-advisor at OFAC and also served as OFAC’s assistant director for transnational threats, where he directed targeting and investigations for more than 25 U.S. economic sanction programs, including those related to Iran and North Korea. In 2007, the United Nations Secretary-General appointed Carlton to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. He also previously served as a trial attorney at the DOJ, where he represented OFAC and other agencies on national security matters in federal district court litigation.

Carlton provides compliance counseling and representation in enforcement matters to global financial and non-financial companies. Based on his years of experience in government and in counseling private companies, Carlton offers valuable insights on the approaches of OFAC, FinCEN, DOJ and other agencies that assist his clients to more effectively respond to government investigations and to manage their sanctions and AML risks effectively.

Career & Education

    • Department of the Treasury
      Chief Counsel, Financial Crimes Enforcement Network, 2014–2015
      Acting Chief Counsel, Financial Crimes Enforcement Network, 2013
      Senior Advisor to the Director, Financial Crimes Enforcement Network, 2012–2013
      Assistant Director for Transactional Threats, Office of Foreign Assets Control, 2008–2013
      Attorney-Advisor, Office of Foreign Assets Control, 2006–2007
    • United Nations
      Expert, Al-Qaida/Taliban Monitoring Team, 2007–2008
    • Department of Justice: Federal Programs Branch
      Trial Attorney, 2003–2006
    • Department of the Treasury
      Chief Counsel, Financial Crimes Enforcement Network, 2014–2015
      Acting Chief Counsel, Financial Crimes Enforcement Network, 2013
      Senior Advisor to the Director, Financial Crimes Enforcement Network, 2012–2013
      Assistant Director for Transactional Threats, Office of Foreign Assets Control, 2008–2013
      Attorney-Advisor, Office of Foreign Assets Control, 2006–2007
    • United Nations
      Expert, Al-Qaida/Taliban Monitoring Team, 2007–2008
    • Department of Justice: Federal Programs Branch
      Trial Attorney, 2003–2006

    • College of William & Mary, B.A., Philosophy, 1993
    • College of William & Mary Marshall-Wythe School of Law, J.D., 1997
    • College of William & Mary, B.A., Philosophy, 1993
    • College of William & Mary Marshall-Wythe School of Law, J.D., 1997

    • District of Columbia
    • Virginia (Inactive)
    • District of Columbia
    • Virginia (Inactive)

Carlton's Insights

Client Alert | 4 min read | 08.06.25

FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers

Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.  ...

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Insights

Client Alert | 4 min read | 08.06.25

FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers

Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

Firm News | 4 min read | 06.26.25

Crowell Earns Top Rankings from Legal 500 United States 2025

Client Alert | 6 min read | 05.27.25

U.S. Departments of State and Treasury Issue Immediate Sanctions Relief for Syria

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Practices

Industries

Carlton's Insights

Client Alert | 4 min read | 08.06.25

FinCEN Delays Implementation Date and Reopens AML/CFT Rule for Investment Advisers

Historically, SEC-registered investment advisers have not been subject to comprehensive AML regulation under the Bank Secrecy Act (“BSA”) unless they also qualify as a broker-dealer or other BSA-regulated financial institution. Notwithstanding the absence of a formal requirement to date, many SEC-registered investment advisers have voluntarily adopted AML programs in line with industry expectations and investor demands. However, on August 28, 2024, FinCEN issued its Final Rule, establishing anti-money laundering/countering the financing of terrorism (“AML/CFT”) requirements for Covered Advisers similar to those that apply to broker-dealers. The Final Rule, which was scheduled to take effect on January 1, 2026, required Covered Advisers to maintain written AML programs, perform customer due diligence, file Suspicious Activity Reports (“SARs”) and other reports required of BSA-regulated financial institutions, and retain standard AML records.  ...

View All Insights