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. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, cybersecurity, cross border data transfers, and investigations. Caroline also advises companies navigating review by the Committee on Foreign Investment in the United States (CFIUS).
Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. 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.
Prior to joining Treasury, Caroline was an Attorney-Advisor in the National Security Division of the U.S. Department of Justice (DOJ). In that role, Caroline made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by CFIUS and the group of U.S. government agencies known as “Team Telecom.” She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements. During her tenure at DOJ, Caroline also worked on counterterrorism, counterespionage, and cybersecurity matters and gained unique insight into issues surrounding data privacy and cybersecurity.
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 in 2008-2009. 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, 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
Admitted to practice: District of Columbia, New York
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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"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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"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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"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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"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, Paul M. Rosen, Nicole Sayegh Succar, Brian McGrath
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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, Aurora Zhang, 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, Aurora Zhang, 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, Paul M. Rosen, 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, Michelle Ann Gitlitz, 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
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"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
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"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, Frances P. Hadfield, Brian McGrath
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"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
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"Team Telecom Opposes United States-Hong Kong Communications Link,"
International Trade Bulletin
(June 19, 2020).
Contact: Caroline E. Brown
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"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, Brian McGrath, Carlton Greene, David (Dj) Wolff, Nicole Sayegh Succar
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"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
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"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, Michelle Ann Gitlitz, Carlton Greene, Jorge Pesok, Nicole Sayegh Succar
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"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
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"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
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"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
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"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
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"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
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"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, Nicole Sayegh Succar, Nimrah Najeeb
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"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
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"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
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"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
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"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
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"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
Media Mentions
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The Year Of Living Dangerously?
January 14, 2021 — Export Compliance Manager
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Stacey Cunningham, NYSE President Caught Up In Sino-US Tension
January 8, 2021 — Financial Times
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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
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What’s At Stake For Hollywood In The Presidential Election?
October 30, 2020 — Variety
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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
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Confusion Prevails Over Extent Of Trump's TikTok 'Ban'
August 10, 2020 — Law360
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Back To The Rink
July 28, 2020 — WorldECR
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The Biggest Telecom Developments Of 2020: Midyear Report
July 21, 2020 — Law360
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Harvard Professor's Trial Should Crystallise US Message To Universities
June 26, 2020 — Global Investigations Review
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Data Security Risks Threaten Approval Of Chinese Undersea Cable Plan
June 25, 2020 — CSO Online
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CFIUS Focuses On Chips, Lawyers Say; Expert Seeks Balanced US Approach To China
June 25, 2020 — Communications Daily
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US Prosecutors Send A Message With Blockbuster North Korea Charges
June 2, 2020 — Global Investigations Review
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Securing The Remote Bank Workforce
May 18, 2020 — ABA Banking Journal
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Exec. Order Solidifies Team Telecom, But Gray Areas Remain
April 30, 2020 — Law360
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USTR Among Agencies Recommending FCC Revoke License Of Chinese SOE
April 10, 2020 — Inside U.S. Trade
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Regulatory Expectations Increasing For Sanctions Compliance Amid COVID-19, Trade Lawyers Say
April 3, 2020 — Export Compliance Daily
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Expect Less Efficient Sanctions-Alert Management During COVID-19, Keep Regulators Apprised-Legal Experts
April 3, 2020 — Thomson Reuters
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Revolving-Door Roundup: Crowell & Moring, Wachtell, MoFo
March 31, 2020 — Law360
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Former US Treasury Lawyer Moves To Crowell & Moring
February 25, 2020 — Global Trade Review
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Crowell & Moring Nabs Former Government National Security Advisor
February 21, 2020 — Global Investigations Review
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Crowell & Moring Lands Former Treasury, DOJ Official
February 20, 2020 — Bloomberg Law
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Crowell & Moring Hires 10-Year Treasury & DOJ Alum In DC
February 20, 2020 — Law360
Firm News & Announcements