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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

Blog Post | 10.08.26

Proposed Third-Party Guidance: What It Means for Sponsor Banks and Fintechs

In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed Federal Reserve guide for traditional community banks (the “Community Bank Guide”).2 This blog post covers what these agency pronouncements mean for fintechs and the banks that sponsor their programs....

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Insights

Blog Post | 10.08.26

Proposed Third-Party Guidance: What It Means for Sponsor Banks and Fintechs

Press Coverage | 10.06.26

Fincen scraps crypto mixer rule built to fight ransomware

Client Alert | 12 min read | 09.30.26

From Process to Principles: Federal Regulators Propose a New Third-Party Risk Management Framework

Blog Post | 09.29.26

OFAC Creates Unified Sanctions Penalties Regulations

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Practices

Industries

Carlton's Insights

Blog Post | 10.08.26

Proposed Third-Party Guidance: What It Means for Sponsor Banks and Fintechs

In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed Federal Reserve guide for traditional community banks (the “Community Bank Guide”).2 This blog post covers what these agency pronouncements mean for fintechs and the banks that sponsor their programs....

View All Insights