Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & 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).
Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.
Most recently, she served as an Attorney-Advisor in the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), where she developed an in-depth understanding of AML regulation and enforcement and FinCEN’s role in guarding the U.S. financial system against money laundering and terrorist financing. Before joining FinCEN, she served as an attorney in the Treasury Department’s Office of General Counsel, Enforcement and Intelligence, which provides counsel to the Undersecretary for Terrorism and Financial Intelligence. There, Caroline advised on sanctions, AML, and various other national security issues relevant to the nation’s financial system.
While at DOJ, Caroline was detailed to the White House for a year, where she coordinated communications strategy focused on national security. She previously worked on the 2008 Obama Presidential Campaign and served on the Obama Presidential Transition Team from 2008 to 2009. Her time at the White House as well as at Treasury and DOJ has given her significant experience managing rapid response and crisis communications.
Caroline’s time in government has enabled her to build strong relationships at senior levels across a number of U.S. government agencies, including DOJ, the FBI, the National Intelligence Council and other components of the Intelligence Community, the FCC, and the Departments of Defense, Homeland Security, State, Energy, Commerce, and the Treasury.
Caroline began her legal career as a law clerk for the Honorable Jon McCalla in the U.S. District Court for the Western District of Tennessee before joining the litigation group of a global law firm in Washington, D.C. She is a former term member on the Council on Foreign Relations, a National Security Fellow at the Foundation for the Defense of Democracies, an Aspen Institute Socrates Scholar, and a Young Leader of the transatlantic organization Atlantik-Brucke.
Affiliations
Professional Activities and Memberships
- Council on Foreign Relations, Term Member (former)
- National Security Fellow, Foundation for the Defense of Democracies
- Socrates Scholar, Aspen Institute
- Atlantik-Brucke
Speeches & Presentations
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"Addressing Unique Issues Relating to Purchases of Non-U.S. Registered Aircraft," Crowell & Moring Webinar, 2023.
(March 22, 2023).
Speakers: Caroline E. Brown, Christopher B. Younger
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"Corporations and National Security: Is the Private Sector the New Battleground?" 28th Annual National Security Law Conference, Durham, NC.
(February 24, 2023).
Speaker: Caroline E. Brown.
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"Blockchain, Crypto, Bored Apes, Oh My!" National Association of Women Lawyers Webinar, 2022.
(October 4, 2022).
Speakers: Caroline E. Brown.
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"Takeaways on Balancing How to Maintain Open Investment Policy while Protecting National Security," American Conference Institute, Washington, D.C.
(April 27, 2022).
Speakers: Caroline E. Brown.
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"Ukraine Crisis Webinar," Crowell & Moring Webinar, 2022.
(April 21, 2022).
Speakers: Vass Akritidis, Bryan Brewer, Caroline Brown, Carlton Greene, Andrew Martin, John Murino, Nicole Simonian, Rob Sneckenberg, Scott Winkelman, Dj Wolff, Alex Urbelis, and Laura Baker
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"Russia Sanctions Two Months In: Where Are We and Where Are We Headed," National Contract Management Association
(April 19, 2022).
Presenters: Caroline Brown, Carlton Greene, Brian McGrath, Anand Sithian, Nicole Succar and Dj Wolff.
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"Analysis of the Evolving US Sanctions on Russia and the Impact on the Loan Market," LSTA University Webinar 2022.
(March 9, 2022).
Speakers: Caroline E. Brown, Dj Wolff, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Robert Clifton Burns.
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"Russia-Related Sanctions Developments," Crowell & Moring Webinar
(March 2, 2022).
Speakers: Caroline E. Brown, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Lorenzo Di Masi, Anand Sithian, and Nicole Sayegh Succar.
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"Cybersecurity: Can the Intelligence Community and the Private Sector Collaborate," Duke Law School's 27th Annual National Security Law Conference, Durham, N.C.
(February 25, 2022).
Speaker: Caroline E. Brown
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"Supply Chain Webinar Series: White Collar & Regulatory Enforcement Issues," Crowell & Moring Webinar
(February 24, 2022).
Speakers: Caroline E. Brown, Derek A. Hahn, Agustin Orozco and Tiffany Wynn.
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"3rd Virtual Conference on U.S.-China Trade Controls," American Conference Institute
(September 20, 2021).
Speaker: Caroline Brown.
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"Are you Prepared for a Ransomware Attack? Preparing for Threats and Managing the Crisis"
(July 21, 2021).
Presenters: Michael K. Atkinson, Caroline E. Brown, Laura Foggan, Kristin J. Madigan, CIPP/US, Jeffrey L. Poston, Evan D. Wolff.
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"National Security: Strengthening Alliances & Global Engagement with Continued Focus on Foreign Adversaries & Emerging Technologies," 7th Annual Ounce of Prevention Seminar
(May 13, 2021).
Presenter: Michael K. Atkinson, Caroline E. Brown, Adelicia R. Cliffe, and Maria Alejandra (Jana) del-Cerro.
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"Non-Fungible Tokens (NFTs) 101: What’s All the Hype?" Crowell & Moring Webinar
(May 4, 2021).
Presenters: Caroline E. Brown, Michelle Ann Gitlitz, Michel C. Narganes, and Carissa Wilson.
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"Trade Secrets Investigations," Investigations: Readiness and Response Webinar Series
(April 29, 2021).
Presenters: Caroline E. Brown, Stephen M. Byers, Astor Heaven, Christine B. Hawes, and Raija Horstman.
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"Congressional Investigations & National Security," Investigations: Readiness and Response Webinar Series
(April 27, 2021).
Presenters: Michael K. Atkinson, Caroline E. Brown, Adelicia R. Cliffe, James G. Flood, Paul M. Rosen, and Byron R. Brown.
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"Digital Asset Enforcement Trends: Getting Your House in Order," Crowell & Moring Webinar
(April 9, 2021).
Moderator: Caroline E. Brown; Presenters: Carlton Greene and Michelle Ann Gitlitz.
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"Team Telecom 2.0: Examining the New Team Telecom Environment in the Aftermath of Executive Order 13913 and A Deep Dive into the FCC’s Recent Implementation Guidelines," American Conference Institute National Forum on Team Telecom
(March 17, 2021).
Presenter: Caroline E. Brown.
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"International Trade in 2021: What’s Ahead," Crowell & Moring Webinar
(February 17, 2021).
Presenters: Vassilis Akritidis, Caroline E. Brown, Michelle J. Linderman, Joshua Pond, Nicole Janigian Simonian, David R. Stepp, Robert Clifton Burns, Carina C. Federico, Jackson C. Pai, Nicole Sayegh Succar, Michael Bowen, Chandler S. Leonard, Brian McGrath, Nimrah Najeeb, and Joshua Boswell.
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"Part 1 - Higher Education and the Biden Administration’s Priorities: Are there significant changes ahead?" Crowell & Moring Webinar
(January 19, 2021).
Presenters: Amanda Shafer Berman, Caroline E. Brown, Astor Heaven, Laurel Pyke Malson, Rebecca L. Springer, Suzanne E. Rode, and Eli Berns-Zieve
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"The US Response to China's Theft and Acquisition of Trade Secrets," AIPLA CLE Webinar
(January 13, 2021).
Presenters: Caroline E. Brown and James K. Stronski.
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"Caught Between a Rock and a Hard Place: The Impact of Dueling Tech Regulations and Escalating Tensions on Cross-Border Transactions," Crowell & Moring Webinar
(November 19, 2020).
Presenters: Vassilis Akritidis, Evan Y. Chuck, Robert Holleyman, and Caroline E. Brown.
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"Protecting Sensitive Data and the Race for 5G: CFIUS, Team Telecom, the Clean Network program, and the TikTok and WeChat Executive Orders," Crowell & Moring Webinar
(October 26, 2020).
Presenters: Caroline E. Brown, Adelicia R. Cliffe, and Kate M. Growley.
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"Election 2020: U.S. International Trade Policy and Its Impact on Cross-Border Business Strategy," Crowell & Moring Webinar
(October 15, 2020).
Presenters: Caroline E. Brown, Evan Y. Chuck, Robert Holleyman, Clark Jennings, and Shelley Su.
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"The U.S. Response to China’s Theft and Acquisition of Trade Secrets," Crowell & Moring Webinar
(September 29, 2020).
Presenters: Caroline E. Brown and James K. Stronski.
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"China in the Crosshairs: An Overview of the U.S. Approach to Mitigating National Security Concerns," Crowell & Moring Webinar
(June 23, 2020).
Presenters: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, David R. Stepp, Gail D. Zirkelbach, Erik Woodhouse, Stephanie L. Crawford, Chandler S. Leonard, and Andrew Blasi.
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"Emerging Issues in Sanctions, AML and Everything in Between in the Time of COVID-19: 2020 AML & Sanctions Risk Considerations for Digital Assets Companies," Crowell & Moring Webinar
(May 19, 2020).
Presenters: Caroline E. Brown, Michelle Gitlitz, Carlton Greene, Michelle J. Linderman, David (Dj) Wolff, Nicole Sayegh Succar, and Erik Woodhouse.
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"Emerging Issues in Sanctions, AML and Everything in Between: Managing an AML Program in the Time of COVID-19 – Adjusting Operations and Dealing with Paycheck Protection Program Loans Under the CARES Act," Crowell & Moring Webinar
(April 28, 2020).
Presenters: Caroline E. Brown, Carlton Greene, and Erik J. Woodhouse.
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"Critical Issues in the Cannabis Space," Crowell & Moring Webinar
(April 23, 2020).
Presenters: Caroline E. Brown, Anne Elise Herold Li, Eric Su, and Nicole Sayegh Succar.
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"COVID-19: 'Virtual' Sanctions Compliance: Managing Your Team and Getting Your Regulatory Updates While Remote," Crowell & Moring Webinar
(April 2, 2020).
Presenters: Caroline E. Brown, Michelle J. Linderman, David (Dj) Wolff, and Nicole Sayegh Succar.
Publications
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"US' New China Tech Unit Raises Domestic Research Scrutiny," Law360
(March 17, 2023).
Authors: Caroline E. Brown, Michael K. Atkinson, Jeremy Iloulian, and Kelsey Clinton.
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"Sanctions/Export Highlights [As of May 6, 2022]" Crowell & Moring’s International Trade Law Blog
(May 6, 2022).
Authors: Jeffrey L. Snyder, Carlton Greene, Michelle Linderman, Caroline Brown, Nicole Succar, Anand Sithian, Brian McGrath, Laurel Saito, and Rachel Schumacher.
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"Russia Sanctions/Export Highlights [As of April 28, 2022]" Crowell & Moring’s International Trade Law Blog
(April 28, 2022).
Authors: Caroline Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Laurel Saito, and Rachel Schumacher.
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"Sanctions/Export Highlights [As of April 7, 2022]" Crowell & Moring’s International Trade Law
(April 8, 2022).
Authors: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Edward Goetz and Laurel Saito.
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register," The Banking Law Journal
(December 6, 2021).
Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Anand Sithian, and Christopher Murphy.
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"Blockchain & Cryptocurrency Regulation 2022 - An Introduction To Virtual Currency Money Transmission Regulation," Global Legal Insights
(November 8, 2021).
Author: Carlton Greene, Caroline E. Brown, and Michelle Gitlitz.
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"New York Governor Kathy Hochul Announces Nomination of Adrienne Harris as Superintendent of the New York Department of Financial Services," Crowell & Moring’s International Trade Law
(September 2, 2021).
Authors: Caroline E. Brown, Carlton Greene, Anand Sithian, Frances P. Hadfield and Martín Yerovi.
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"FinCEN Issues Major Anti-Money Laundering Act Announcements And Appoints New Chief Digital Currency Advisor," Westlaw Today
(July 30, 2021).
Authors: Caroline E. Brown, Michelle Ann Gitlitz, Carlton Greene, Anand Sithian.
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"U.S. Government Issues Business Advisory – Warns Companies About Risks of Doing Business in Hong Kong," Crowell & Moring’s International Trade Law
(July 16, 2021).
Authors: Caroline E. Brown, Evan Y. Chuck, David (Dj) Wolff, Anand Sithian, Frances P. Hadfield and Martín Yerovi.
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"Agency Issues First National Priorities for Anti-Money Laundering and Counter-Terrorist Financing, Completes Assessment on Potential No-Action Letter Process, Provides 180-Day Update on AML Act Implementation, and Appoints First-Ever Chief Digital Currency Advisor," Crowell & Moring’s International Trade Law
(July 15, 2021).
Authors: Caroline E. Brown, Kelly T. Currie, Michelle Ann Gitlitz, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian and Nicole Sayegh Succar.
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"Commerce Publishes ANPRM Seeking Comment On The Licensing Process For ICTS Transactions," Westlaw Today
(April 28, 2021).
Authors: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra del-Cerro, and Alan W.H. Gourley.
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"Florida Lawmakers Seek to Address Corporate Espionage in Proposed Legislation," Crowell & Moring’s Trade Secrets Trends
(March 9, 2021).
Authors: Molly A. Jones, Caroline E. Brown and Kevin D. Cacabelos.
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"OFAC Designates Entities Determined to be Involved in Exporting Workers from North Korea," Crowell & Moring’s International Trade Law
(December 9, 2020).
Authors: Jeffrey L. Snyder, Caroline E. Brown and Chandler S. Leonard.
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"Dueling Tech Regulations And Escalating Tensions On Cross-Border Transactions," WorldECR
(December 9, 2020).
Authors: Caroline E. Brown, and Evan Y. Chuck.
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"Grand Jury Indicts Chinese Energy Company, U.S. Oil and Gas Affiliate, and Chinese National on Trade Secrets Charges," Crowell & Moring’s Trade Secrets Trends
(November 25, 2020).
Authors: Jillian Ambrose, Vincent J. Galluzzo and Caroline E. Brown.
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"Taiwanese Semiconductor Pleads Guilty, To Pay $60 Million Fine for Criminal Trade Secret Theft," Crowell & Moring’s Trade Secrets Trends
(November 23, 2020).
Authors: Caroline E. Brown, Mark A. Klapow and Eli Berns-Zieve.
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"Managing An AML Program During COVID-19," ABA Banking Journal: Risk & Compliance
(September 17, 2020).
Authors: Caroline E. Brown, Carlton Greene, and Erik Woodhouse.
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"Trump's TikTok, WeChat Orders May Yield Different Results," Law360
(August 6, 2020).
Authors: Caroline E. Brown, and Robert Holleyman.
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"Recent FinCEN Advisories on Medical and Consumer Fraud Scams Related to the COVID-19 Pandemic," Crowell & Moring’s International Trade Law
(July 29, 2020).
Authors: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar and Alex Rosen.
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"Circling The Wagons: Reactions To Covid-19 Bolster Regulatory Exclusions," WorldECR
(July 28, 2020).
Authors: Caroline E. Brown, and Chandler S. Leonard.
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"FinCEN Issues Alert to Financial Institutions Regarding Scam Involving Twitter," Crowell & Moring’s International Trade Law
(July 22, 2020).
Authors: Carlton Greene, Caroline E. Brown, Erik Woodhouse, Michelle Ann Gitlitz and Justin Porter.
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"Security Fears Over HK Cable Reveal 'Team Telecom' Priorities," Law360
(July 8, 2020).
Author: Caroline E. Brown.
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"Sanctions Order May Accelerate Decline In US-ICC Relations," Law360
(June 22, 2020).
Authors: Caroline E. Brown, Erik Woodhouse, Brian McGrath, Carlton Greene, David Wolff, and Nicole Sayegh Succar.
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"OFAC Publishes Additional Iran-Related FAQs Related to Executive Order 13902," Crowell & Moring’s International Trade Law
(June 9, 2020).
Authors: Caroline E. Brown and Brian McGrath.
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"INSIGHT: ‘Team Telecom’ Advice to FCC to Bar China Telecom From U.S. Sets Trend," Bloomberg Law
(May 8, 2020).
Author: Caroline E. Brown.
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"Team Telecom Recommends The FCC Revoke China Telecom’s Authorisations To Provide International Telecoms Services," WorldECR
(May 2020).
Author: Caroline E. Brown.
Client Alerts & Newsletters
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"The United States Imposes New Sanctions and Export Controls Targeting Russia and Belarus, Issues Joint Compliance Guidance, and Announces Corporate Compliance with Sanctions and Export Controls as an Enforcement Priority,"
International Trade Bulletin
(March 10, 2023).
Contacts: Caroline E. Brown, Weronika Bukowski, Carlton Greene, Jason Prince, Anand Sithian, David (Dj) Wolff
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"New U.S. Disruptive Technology Strike Force Highlights Risks for Research Facilities and Universities in the U.S.-China Competition for Technical Supremacy,"
White Collar Alert
(February 24, 2023).
Contacts: Michael K. Atkinson, Caroline E. Brown, Jeremy Iloulian, Kelsey Clinton
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"CFIUS Formalizes Its Enforcement and Penalty Process,"
International Trade Bulletin
(October 27, 2022).
Contacts: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley, Nimrah Najeeb
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"Biden Administration Announces Presidential Directive on Sharpening Foreign Investment Screening by CFIUS,"
International Trade Bulletin
(September 16, 2022).
Contacts: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley, Jeremy Iloulian, Nimrah Najeeb
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"Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers,"
International Trade Bulletin
(August 17, 2022).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Jackie Schaeffer
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"New Law Gives NYDFS Authority to Make Virtual Currency Business Activities in New York More Expensive,"
Privacy Law Alert
(May 11, 2022).
Contacts: Garylene (Gage) Javier, CIPP/US, Anand Sithian, Carlton Greene, Caroline E. Brown, Kelly T. Currie, Nicole Sayegh Succar
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"Financial Institutions Beware: FDIC Requests “Prompt” Notice of Crypto-Related Activities,"
Financial Services Alert
(April 20, 2022).
Contacts: Carlton Greene, Caroline E. Brown, Stephanie L. Crawford, Alexander Urbelis, Anand Sithian
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"Biden Administration Considers Imposing Sanctions on Kaspersky Labs,"
Privacy Law Alert
(April 6, 2022).
Contacts: Caroline E. Brown, Robert Holleyman, Jeffrey L. Snyder, Evan D. Wolff, Alexander Urbelis
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"President Biden Issues Executive Order Directing “Whole of Government” Assessment of Digital Assets,"
Financial Services Alert
(April 5, 2022).
Contacts: Alexander Urbelis, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown, Richard J. Lee, Irina Pisareva, Carlton Greene
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"SEC Announces 2022 Examination Priorities,"
Financial Services Alert
(April 1, 2022).
Contacts: Carlton Greene, Anand Sithian, Irina Pisareva, Richard J. Lee, Nimrod Haim Aviad, Caroline E. Brown, Alexander Urbelis
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"U.S., EU and UK Escalate Belarus Sanctions,"
International Trade Bulletin
(December 15, 2021).
Contacts: Carlton Greene, Michelle J. Linderman, Nicole Sayegh Succar, Anand Sithian, David (Dj) Wolff, Caroline E. Brown
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"Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics,"
International Trade Bulletin
(November 15, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Sarah Bartle, Anand Sithian, Nicole Sayegh Succar
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"Stablecoin Regulation Is Coming? President’s Working Group Issues Report on Stablecoins Outlining Stablecoin Risks and Requesting Congress Pass Urgent Legislation Regulating Stablecoins,"
Blockchain Alert
(November 15, 2021).
Contacts: Carlton Greene, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown
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"OFAC Issues Updated Guidance on Ransomware Attacks and Imposes First Sanctions Designation on a Virtual Currency Exchange,"
International Trade Bulletin
(September 28, 2021).
Contacts: Caroline E. Brown, Laura Foggan, Carlton Greene, Jeffrey L. Poston, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner, Alexander Urbelis, Anand Sithian, Matthew B. Welling, Rebecca Lennon Baskin
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"FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register,"
Financial Services Alert
(August 25, 2021).
Contacts: Carlton Greene, Caroline E. Brown, Anand Sithian, Nicole Sayegh Succar, Chris Murphy
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"Byte-Sized Q&A: Paying a Criminal: Ransomware Payments and Related Sanctions Risks,"
Podcast: Byte-Sized Q&A
(July 29, 2021).
Contact: Caroline E. Brown
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"FinCEN Issues Major Anti-Money Laundering Act Announcements and Appoints New Chief Digital Currency Advisor,"
Financial Services Alert
(July 14, 2021).
Contacts: Caroline E. Brown, Kelly T. Currie, Carlton Greene, Rebecca Monck Ricigliano, Anand Sithian, Nicole Sayegh Succar
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"Don’t be that Victim: The Critical Need for Ransomware Response Plans,"
Privacy Law Alert
(June 23, 2021).
Contacts: Michael K. Atkinson, Caroline E. Brown, Laura Foggan, Carlton Greene, Michelle J. Linderman, Jeffrey L. Poston, Matthew B. Welling, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner
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"Executive Order Rescinds TikTok and WeChat Prohibitions But Continues to Focus on Vulnerabilities in the ICTS Supply Chain,"
(June 17, 2021).
Contacts: Caroline E. Brown, Stephanie L. Crawford
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"A Ransomware Attack Primer: What You Need to Know and What Crowell Can Do to Help,"
Privacy Law Alert
(June 17, 2021).
Contacts: Michael K. Atkinson, Caroline E. Brown, Laura Foggan, Carlton Greene, Michelle J. Linderman, Jeffrey L. Poston, Matthew B. Welling, David (Dj) Wolff, Evan D. Wolff, Maida Oringher Lerner
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"Biden’s First 100 Days: Developments to Date and What Lies Ahead,"
Administrative Law Alert
(May 7, 2021).
Contacts: James G. Flood, Michael K. Atkinson, Tim Shadyac, Troy A. Barsky, Byron R. Brown, Caroline E. Brown, Robert A. Burton, Matthew Cohen, Kelly T. Currie, Jodi G. Daniel, W. Scott Douglas, Carina C. Federico, Paul Freeman, Thomas P. Gies, Alexis J. Gilman, Christine B. Hawes, Robert Holleyman, Stacie Heller, S. Starling Marshall, Shelley Su, Jeane A. Thomas, CIPP/E, Scott L. Winkelman, Tiffany Wynn, Kate Beale
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"DOJ Appointments at the Top and Recent Enforcement Actions Signal That Its China Initiative Will Likely Remain Intact,"
White Collar Alert
(April 23, 2021).
Contacts: Michael K. Atkinson, Caroline E. Brown, Laura Schwartz
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"SEC Risk Alert Provides Valuable Reminders Concerning Importance of Compliance with SAR Reporting Requirements,"
Administrative Law Alert
(April 21, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Tiffany Wynn, Allison Skager
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"FinCEN Seeks Comment on Beneficial Ownership Reporting Requirements,"
Administrative Law Alert
(April 16, 2021).
Contacts: Caroline E. Brown, Carlton Greene, Rebecca Monck Ricigliano, Laura Schwartz, Nicole Sayegh Succar, Allison Skager
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"President Biden Imposes Additional Sanctions on Russia,"
International Trade Bulletin
(April 16, 2021).
Contacts: David (Dj) Wolff, Carlton Greene, Caroline E. Brown, Robert Clifton Burns, Nicole Sayegh Succar, Laurel Saito
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"Commerce Publishes ANPRM Seeking Comment on the Licensing Process for ICTS Transactions,"
Administrative Law Alert
(March 29, 2021).
Contacts: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley
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"FinCEN Issues Notice Related to the Trade of Antiquities and Art,"
Administrative Law Alert
(March 24, 2021).
Contacts: Caroline E. Brown, Carlton Greene
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"OFAC's First Enforcement Actions Against Digital Currency Service Providers,"
Administrative Law Alert
(March 8, 2021).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar, Laurel Saito
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"Newly Proposed Cyber Reporting Rules for Banking Organizations,"
Administrative Law Alert
(February 1, 2021).
Contact: Caroline E. Brown
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"Podcast: Impact of FRB and FinCEN Proposed Amendments to Recordkeeping and Travel Rule Regulations,"
International Trade Bulletin
(January 22, 2021).
Contacts: Caroline E. Brown, Carlton Greene
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"FCC Publishes Telecommunications Supply Chain Security Rule,"
Government Contracts Bullet Points
(January 21, 2021).
Contacts: Caroline E. Brown, Adelicia R. Cliffe, Stephanie L. Crawford
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"Not Your Parents' IT: New Interim Rule to Scrutinize Acquisition of IT Products and Services from Foreign Adversaries,"
Government Contracts Bullet Points
(January 19, 2021).
Contacts: Alan W. H. Gourley, Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro
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"Congress Passes the Anti-Money Laundering Act of 2020, Significant Changes to the Bank Secrecy Act Ahead,"
International Trade Bulletin
(January 19, 2021).
Contacts: Carlton Greene, Caroline E. Brown, Nimrod Haim Aviad, Kelly T. Currie, Rebecca Monck Ricigliano, Nicole Sayegh Succar
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"Executive Order Prohibits Transactions with Eight Chinese Software Applications,"
International Trade Bulletin
(January 8, 2021).
Contacts: Caroline E. Brown, Evan Y. Chuck, Robert Holleyman
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"China Issues Rules Governing National Security Reviews of Foreign Investment,"
(December 23, 2020).
Contacts: Olivier N. Antoine, Caroline E. Brown, Evan Y. Chuck, Zhongdong Zhang
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"White House Issues Executive Order Prohibiting Investments that Finance Communist Chinese Military Companies,"
International Trade Bulletin
(November 17, 2020).
Contacts: Caroline E. Brown, Evan Y. Chuck, Maria Alejandra (Jana) del-Cerro, Robert Holleyman, David (Dj) Wolff
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"China Unveils Draft Personal Information Protection Law,"
International Trade Bulletin
(October 30, 2020).
Contacts: Caroline E. Brown, Zhiwei Chen, Evan Y. Chuck, Robert Holleyman, Clark Jennings, Zhongdong Zhang
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"OFAC Targets Iran’s Financial Sector and Designates Additional Iranian Banks,"
International Trade Bulletin
(October 28, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, David (Dj) Wolff, Nicole Sayegh Succar, Chandler S. Leonard
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"OFAC and FinCEN Release Advisories on Risks of Ransomware Payments,"
International Trade Bulletin
(October 8, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Evan D. Wolff
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"FinCEN Issues Final Rule Establishing Anti-Money Laundering Requirements for State-Regulated Banks,"
International Trade Bulletin
(September 28, 2020).
Contacts: Carlton Greene, Caroline E. Brown, Nicole Sayegh Succar
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"FinCEN Issues ANPRM Seeking Comment on Requirement for an "Effective and Reasonably Designed" AML Program,"
International Trade Bulletin
(September 24, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"CFIUS Mandatory Declarations – Bye, Bye NAICS Codes; Hello "Regulatory Authorizations","
Government Contracts Bullet Points
(September 15, 2020).
Contacts: Alan W. H. Gourley, Maria Alejandra (Jana) del-Cerro, Adelicia R. Cliffe, Caroline E. Brown
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"FinCEN Issues New Guidance for Complying with the CDD Rule,"
International Trade Bulletin
(August 18, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
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"CFIUS Review Culminates in Order Directing ByteDance, Ltd. to Divest TikTok,"
(August 18, 2020).
Contacts: Caroline E. Brown, Robert Holleyman
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"New Executive Orders Start Clock Ticking for TikTok and WeChat,"
International Trade Bulletin
(August 11, 2020).
Contacts: Caroline E. Brown, Robert Holleyman
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"Creation of a New Hong Kong-Related Sanctions Program,"
(July 17, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
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"FinCEN Provides Additional Guidance for Financial Institutions on Hemp-Related Businesses,"
International Trade Bulletin
(July 10, 2020).
Contacts: Caroline E. Brown, Carlton Greene, John Fuson, Nicole Sayegh Succar
-
"DOE Seeks Information on Securing Bulk Power System,"
Energy Law Alert
(July 9, 2020).
Contacts: Larry F. Eisenstat, Alan W. H. Gourley, Caroline E. Brown, Deborah A. Carpentier
-
"New Legislation and Guidance Aimed at Addressing Forced Labor in Xinjiang, China,"
(July 2, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, David (Dj) Wolff
-
"U.S. Government Issues First Designations under the Caesar Act as Part of Larger Set of Designations Targeting the Syrian Government,"
International Trade Bulletin
(June 25, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
-
"Team Telecom Opposes United States-Hong Kong Communications Link,"
International Trade Bulletin
(June 19, 2020).
Contact: Caroline E. Brown
-
"President Issues Executive Order Authorizing Sanctions on Certain Persons Associated with the International Criminal Court,"
International Trade Bulletin
(June 17, 2020).
Contacts: Caroline E. Brown, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
-
"FinCEN’s Suspicious Activity Report Renewal Notice Seeks Public Comment on SAR Burden Estimates,"
International Trade Bulletin
(June 1, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
-
"FinCEN Director Identifies Virtual Currency Compliance Risks and COVID-19 Related Issues at Consensus 2020 Conference,"
White Collar Alert
(May 20, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
-
"Key Lessons Learned as OFSI Begins to Flex its Muscles,"
International Trade Bulletin
(May 19, 2020).
Contacts: Michelle J. Linderman, David (Dj) Wolff, Caroline E. Brown, Carlton Greene
-
"New U.S. Sanctions Advisory for the Maritime Industry,"
International Trade Bulletin
(May 15, 2020).
Contacts: David (Dj) Wolff, Michelle J. Linderman, Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar, Nimrah Najeeb
-
"Industrial Bank of Korea Agrees to a Deferred Prosecution Agreement and $86 Million in Penalties for Violations of the Bank Secrecy Act That Allowed Evasion of Sanctions on Iran,"
International Trade Bulletin
(May 13, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Nicole Sayegh Succar
-
"Scrutiny of Foreign Ownership in the Telecommunications Sector Gains Momentum with the FCC’s Issuance of Show Cause Orders and a Recent Public Notice Refreshing the Team Telecom Record and Requesting Comments,"
International Trade Bulletin
(May 7, 2020).
Contact: Caroline E. Brown
-
"President Declares Threat to Electric Power Grid a National Emergency,"
Government Contracts Bullet Points
(May 4, 2020).
Contacts: Alan W. H. Gourley, Larry F. Eisenstat, Caroline E. Brown, Robert Holleyman, Deborah A. Carpentier, Byron R. Brown
-
"OFAC Issues Fact Sheet Regarding Humanitarian Trade Involving Sanctioned Countries and Provides COVID-19 Guidance,"
International Trade Bulletin
(April 24, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Jeffrey L. Snyder, David (Dj) Wolff, Robert Clifton Burns, Nimrah Najeeb, Nicole Sayegh Succar
-
"TeamTelecom Recommends that the FCC Revoke China Telecom’s Authorizations to Provide International Telecommunications Services to and from the United States,"
International Trade Bulletin
(April 10, 2020).
Contact: Caroline E. Brown
-
"FinCEN Provides Relief to Application of Beneficial Ownership Requirements to Certain CARES Act Loans and Suspends Implementation of CTR Filing Changes,"
International Trade Bulletin
(April 8, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Scott Lessne
-
"President Issues Executive Order Formalizing "Team Telecom" and Executive Branch Review of Foreign Involvement in Telecommunications Transactions,"
International Trade Bulletin
(April 7, 2020).
Contacts: Caroline E. Brown, Adelicia R. Cliffe, Alan W. H. Gourley
-
"Anti-Money Laundering Program Contingency Planning during COVID-19: Recent Guidance from FinCEN and FFIEC,"
International Trade Bulletin
(March 26, 2020).
Contacts: Caroline E. Brown, Carlton Greene, Scott Lessne
-
"Iran Petroleum and Petrochemical Designations,"
International Trade Bulletin
(March 23, 2020).
Contacts: Nicole Sayegh Succar, Carlton Greene, Caroline E. Brown, David (Dj) Wolff, Michelle J. Linderman
Press Coverage
-
Biden Directs CFIUS To Focus On Cybersecurity, Supply Chain
September 19, 2022 — CQ Roll Call
-
Biden Warns Cfius On Serial Acquisitions
September 16, 2022 — The Deal
-
We Crowdsource Key Takeaways From CFIUS’ First Conference
July 3, 2022 — Foreign Investment Watch
-
Continuing To Do Business In Russia Carries Risks, But So Does Decoupling, Lawyers Say
April 25, 2022 — Export Compliance Daily
-
What Russian Sanctions Mean For Fashion
March 28, 2022 — Business of Fashion
-
Policy Scoop With Aislinn Keely: Legal And Crypto Exchange Experts Weigh In On How To Navigate Sanctions
March 28, 2022 — The Block
-
U.S. Sanctions Lawyers Are Busier Than Ever. Here's What Clients Want To Know
March 17, 2022 — Reuters
-
Law Firms Scramble To Keep Pace With Unprecedented Russian Sanctions
March 14, 2022 — ABA Journal
-
Compliance Scramble Intensifies As Russia Sanctions Stack Up
March 8, 2022 — Reuters
-
Crypto Exchange Executives Respond To Sanction 'Misinformation'
March 5, 2022 — The Block
-
Speed, Complexity of Russia Sanctions Regime Unprecedented, Lawyers Say
March 3, 2022 — Export Compliance Daily
-
Law Firms Dash To Handle Flood Of Russia Sanctions Q's
March 3, 2022 — Law360
-
Could Russian Banks And Oligarchs Use Crypto To Evade Sanctions?
March 2, 2022 — American Banker
-
European, U.S. Bank Shares Recoup Some Losses Ahead Of New EU Sanctions
February 25, 2022 — Reuters
-
Law Firms Gear Up As U.S., Europe Impose New Sanctions On Russia (video)
February 23, 2022 — Reuters
-
Daily Update: February 23, 2022
February 23, 2022 — S&P Global Intelligence
-
NYC Delivery Guys At Russia-Backed App Buyk Worried About Sanctions
February 23, 2022 — New York Post
-
Can Russia's 'De-Dollarisation' Protect its Economy From US Sanctions?
February 22, 2022 — The Quint
-
What Is In Store For Banks If West Hits Moscow With New Sanctions?
February 14, 2022 — S&P Global Intelligence
-
Law Firms Gear Up For Potentially Unprecedented Sanctions If Russia Invades Ukraine (video clip)
February 4, 2022 — Reuters
-
DOJ's China Initiative On Trial As Harvard Prof. Faces Jury
December 10, 2021 — Law360
-
Antiquities Are New Front In AML Battle
December 10, 2021 — Global Association of Risk Professionals
-
Pandora Papers Leak Drops Amid U.S. Anti-Money Laundering Regulatory Overhaul
October 13, 2021 — Kharon
-
Firms Vie For CFIUS Attys As 'Black Box' Panel Extends Reach
July 23, 2021 — Law360
-
Summary Of New Executive Orders And Statements From Biden On FDI
June 15, 2021 — Foreign Investment Watch
-
The Year Of Living Dangerously?
January 14, 2021 — Export Compliance Manager
-
Stacey Cunningham, NYSE President Caught Up In Sino-US Tension
January 8, 2021 — Financial Times
-
Legal Tech’s Predictions For Tech Regulation In 2021
January 5, 2021 — Legaltech News
-
Restrictions On Chinese Investment Will Include Subsidiaries, Experts Say
November 23, 2020 — CQ Roll Call
-
FCC Approves iHeartMedia Request To Take More Foreign Investment
November 10, 2020 — Foreign Investment Watch
-
What’s At Stake For Hollywood In The Presidential Election?
October 30, 2020 — Variety
-
President Trump's Move To Force ByteDance to Sell TikTok Is Part Of A Growing Global Trend Of Countries Scrutinizing Who Owns Their Citizens' Data
September 17, 2020 — Business Insider
-
Confusion Prevails Over Extent Of Trump's TikTok 'Ban'
August 10, 2020 — Law360
-
Back To The Rink
July 28, 2020 — WorldECR
-
The Biggest Telecom Developments Of 2020: Midyear Report
July 21, 2020 — Law360
-
Harvard Professor's Trial Should Crystallise US Message To Universities
June 26, 2020 — Global Investigations Review
-
Data Security Risks Threaten Approval Of Chinese Undersea Cable Plan
June 25, 2020 — CSO Online
-
CFIUS Focuses On Chips, Lawyers Say; Expert Seeks Balanced US Approach To China
June 25, 2020 — Communications Daily
-
US Prosecutors Send A Message With Blockbuster North Korea Charges
June 2, 2020 — Global Investigations Review
-
Securing The Remote Bank Workforce
May 18, 2020 — ABA Banking Journal
-
Exec. Order Solidifies Team Telecom, But Gray Areas Remain
April 30, 2020 — Law360
-
USTR Among Agencies Recommending FCC Revoke License Of Chinese SOE
April 10, 2020 — Inside U.S. Trade
-
Regulatory Expectations Increasing For Sanctions Compliance Amid COVID-19, Trade Lawyers Say
April 3, 2020 — Export Compliance Daily
-
Expect Less Efficient Sanctions-Alert Management During COVID-19, Keep Regulators Apprised-Legal Experts
April 3, 2020 — Thomson Reuters
-
Revolving-Door Roundup: Crowell & Moring, Wachtell, MoFo
March 31, 2020 — Law360
-
Former US Treasury Lawyer Moves To Crowell & Moring
February 25, 2020 — Global Trade Review
-
Crowell & Moring Nabs Former Government National Security Advisor
February 21, 2020 — Global Investigations Review
-
Crowell & Moring Lands Former Treasury, DOJ Official
February 20, 2020 — Bloomberg Law
-
Crowell & Moring Hires 10-Year Treasury & DOJ Alum In DC
February 20, 2020 — Law360
Firm News & Announcements