Caroline E. Brown
Overview
Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar and 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).
Career & Education
- Department of the Treasury
Attorney-Advisor, Office of the General Counsel, Enforcement and Intelligence, 2015–2019
Attorney-Advisor, Financial Crimes Enforcement Network, 2009–2014 - The White House
Detailed from DOJ to the White House Office of Communications, 2010–2011 - Department of Justice: National Security Division
Attorney-Advisor, 2009–2015
- Department of the Treasury
- University of Michigan Law School, J.D., 2002
- Duke University, B.A., 1998
- District of Columbia
- New York
- Law Clerk to the Hon. Jon P. McCalla, U.S. District Court for the Western District of Tennessee, 2002–2003
Professional Activities and Memberships
- Council on Foreign Relations, Life Member
- National Security Fellow, Foundation for the Defense of Democracies
- Socrates Scholar, Aspen Institute
- Atlantik-Brucke
Caroline's Insights
Client Alert | 4 min read | 08.03.26
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List, established through the Secure and Trusted Communications Networks Act to include foreign-produced connected power inverters and advanced robotic devices. The designation of these products to the Covered List follows an Executive Branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment listed on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products absent an exception or approval. This action comes only months after the FCC added consumer-grade routers to the Covered List on March 23, 2026 and uncrewed aircraft systems (UAS) on December 22, 2025. Taken together, these actions reflect the FCC’s increasingly expansive approach to using its authorities to guard against foreign produced connected technologies that may create vulnerabilities enabling disruption of critical infrastructure, unauthorized access to sensitive information, or cyber intrusions. The shift is a departure from the FCC’s previous focus on equipment and services produced by certain PRC and Russian companies.
Client Alert | 4 min read | 07.22.26
Client Alert | 7 min read | 06.24.26
Recognition
- Foreign Investment Watch: Top Advisor, 2024–2026
Caroline's Insights
Client Alert | 4 min read | 08.03.26
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List, established through the Secure and Trusted Communications Networks Act to include foreign-produced connected power inverters and advanced robotic devices. The designation of these products to the Covered List follows an Executive Branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment listed on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products absent an exception or approval. This action comes only months after the FCC added consumer-grade routers to the Covered List on March 23, 2026 and uncrewed aircraft systems (UAS) on December 22, 2025. Taken together, these actions reflect the FCC’s increasingly expansive approach to using its authorities to guard against foreign produced connected technologies that may create vulnerabilities enabling disruption of critical infrastructure, unauthorized access to sensitive information, or cyber intrusions. The shift is a departure from the FCC’s previous focus on equipment and services produced by certain PRC and Russian companies.
Client Alert | 4 min read | 07.22.26
Client Alert | 7 min read | 06.24.26
Insights
- |
06.30.26
Compliance & Enforcement
How To Identify And Mitigate Risks Posed By Foreign Terrorist Organizations
|12.24.25
Compliance Week
- |
07.11.23
The Banking Law Journal
“Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals,” ACSS New York Chapter, New York, NY.
|06.04.26
CFIUS “Black Box” Likely To Remain, Despite New Enforcement Updates
|08.23.24
Global Competition Review
Czech Arms Company Reassures CFIUS Over Purchase Of US Ammunition Business
|04.09.24
Global Competition Review
President Biden Issues Executive Order On Sensitive Personal Data
|03.01.24
Foreign Investment Watch
Treasury Already Seeking Comments On The Outbound Investment Regime
|08.14.23
Foreign Investment Watch
- |
06.15.26
Crowell & Moring's FinTalk
Firewall Up: FCC Bars Foreign-Made Routers in New Covered List Update
|03.30.26
Crowell & Moring’s International Trade Law
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03.16.26
Crowell & Moring’s International Trade Law
- |
02.12.26
Crowell & Moring’s International Trade Law
The FY 2026 National Defense Authorization Act
|12.29.25
Crowell & Moring’s Government Contracts Legal Forum
OFAC Fines U.S. Private Equity Fund for Russian Sanctions Violations
|12.09.25
Crowell & Moring’s International Trade Law
Key Takeaways from a Consequential Month of Russia-Related Sanctions
|10.29.25
Crowell & Moring’s International Trade Law
Practices
Caroline's Insights
Client Alert | 4 min read | 08.03.26
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List, established through the Secure and Trusted Communications Networks Act to include foreign-produced connected power inverters and advanced robotic devices. The designation of these products to the Covered List follows an Executive Branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment listed on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products absent an exception or approval. This action comes only months after the FCC added consumer-grade routers to the Covered List on March 23, 2026 and uncrewed aircraft systems (UAS) on December 22, 2025. Taken together, these actions reflect the FCC’s increasingly expansive approach to using its authorities to guard against foreign produced connected technologies that may create vulnerabilities enabling disruption of critical infrastructure, unauthorized access to sensitive information, or cyber intrusions. The shift is a departure from the FCC’s previous focus on equipment and services produced by certain PRC and Russian companies.
Client Alert | 4 min read | 07.22.26
Client Alert | 7 min read | 06.24.26



