Former U.S. Treasury and Justice Department Lawyer Strengthens Anti-Money Laundering, Economic Sanctions, and CFIUS Practices

Washington, D.C. — February 20, 2020: Crowell & Moring is bolstering its anti-money laundering, economic sanctions, and CFIUS practices with the addition of Caroline Brown, former attorney in the U.S. Department of the Treasury and the U.S. Department of Justice’s National Security Division. Brown joins the firm as a partner in the International Trade and White Collar & Enforcement groups and will be based in Washington, D.C.

Brown will work with financial institutions, multinational corporations, and companies launching emerging technologies to advise clients on anti-money laundering (AML) and economic sanctions compliance and enforcement challenges. She will also help clients navigate review by the Committee on Foreign Investment in the United States (CFIUS).

“We have seen exceptionally strong growth in our AML and economic sanctions practices, and Caroline’s addition is a continuation of our strategy to expand and deepen our experience in these critically important areas,” said Philip T. Inglima, Crowell & Moring chair. “Caroline provides valuable insight from her experience at the Treasury and Justice Departments and can offer strategic counsel to companies investing across borders to compete in global markets governed by complex and conflicting laws and regulations.”

Brown will draw on over a decade of experience in the U.S. Departments of the Treasury and Justice, in addition to her previous experience in private practice. As an attorney advisor at the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), Brown 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, Brown advised on sanctions, AML, and various other national security issues relevant to the nation’s financial system. Before joining Treasury, Brown served in the National Security Division at the Justice Department, where she worked on counterterrorism, counterespionage, and cybersecurity matters, and advised senior DOJ leadership on matters under review by CFIUS and the group of U.S. government agencies known as “Team Telecom.”

“Caroline’s knowledge of how CFIUS reviews petitions will be especially important as the committee continues to expand its reach and examine international companies wanting to do business in the United States,” said Nicole Simonian, co-chair of the firm’s International Trade Group.

Brown earned her undergraduate degrees from Duke University and her law degree from the University of Michigan. She began her legal career as a law clerk for the Honorable Jon McCalla of 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, an Aspen Institute Socrates Scholar, a National Security Fellow at the Foundation for the Defense of Democracies, and a member of the transatlantic organization Atlantik Brücke.

“I am honored to join a firm committed to staying ahead of the rapidly evolving regulatory and enforcement regimes that directly affect companies’ opportunities for growth and innovation,” Brown said. “I look forward to helping clients navigate these frameworks in order to make sound business decisions and move forward.”

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Photo of Caroline Brown Caroline Brown

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…

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.

Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.