On October 20, 2022, the Committee on Foreign Investment in the U.S. (CFIUS) adopted long-awaited CFIUS Enforcement and Penalty Guidelines (the “Guidelines”) identifying how it will review and consider three categories of non-compliances that may be subject to penalties:

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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.

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Photo of Addie Cliffe Addie Cliffe
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Photo of Alan W. H. Gourley Alan W. H. Gourley

Alan W. H. Gourley is a partner in the Washington, D.C. office of the law firm of Crowell & Moring and serves as a member of the Steering Committee for the firm’s Government Contracts Group. He graduated magna cum laude from Beloit College…

Alan W. H. Gourley is a partner in the Washington, D.C. office of the law firm of Crowell & Moring and serves as a member of the Steering Committee for the firm’s Government Contracts Group. He graduated magna cum laude from Beloit College in 1977 and from the University of Virginia School of Law in 1981. He is a member of the District of Columbia bar.

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Photo of Jana del-Cerro Jana del-Cerro
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Photo of Nimrah Najeeb Nimrah Najeeb

Nimrah Najeeb is a counsel in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Nimrah focuses her practice on transactions, investigations and compliance, and advisory matters involving economic sanctions, export controls, anti-money laundering, and other cross-border…

Nimrah Najeeb is a counsel in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Nimrah focuses her practice on transactions, investigations and compliance, and advisory matters involving economic sanctions, export controls, anti-money laundering, and other cross-border international regulatory regimes. She has also advised U.S. and foreign-based multinationals regarding public international law issues, mergers and acquisitions, government and internal investigations, and third-party diligence.

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