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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.

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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EU Updates FAQS to Address Energy Security: On October 7, 2022, the EU updated two FAQs clarifying the impact of Council Regulation 833/2014 on the import, purchase and transfer of listed goods.  The EU clarified that Council Regulation 833/2014 prohibits the transfer of any listed goods if they originate in Russia or are exported from

On September 15, 2022, the Biden Administration issued a new executive order (“EO”) and accompanying fact sheet, designed to sharpen the current U.S. foreign investment screening process as administered by the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”).[1]  This EO is the first to specifically identify certain additional

On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group

Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities.  The amendments included revisions to dates of birth, addresses, and descriptions.

General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384.  The

New UK Sanctions:On July 21, 2022, the UK introduced a new tranche of restrictions in the 14th amendment to its Russian Sanctions Regulations.  Several of the new restrictions are detailed below.

The UK prohibited UK persons from directly or indirectly providing accounting services, business and management consulting services, and public relations services to “

U.S. General Licenses and Guidance: The Office of Foreign Assets Control (“OFAC”) issued four general licenses (“GLs”) this week.  In GL6B, OFAC expanded the authorizations in the previous GL 6A to also permit all transactions “related to…the production, manufacturing, sale, or transport of…agricultural equipment”, in addition to the previously-authorized transactions, including transactions relating to

Sixth Round of EU Sanctions

As previewed in last week’s weekly highlights, the EU published a new round of sanctions on June 3, 2022, which includes a wide range of new restrictions.  Key provisions are summarized below.

The EU now prohibits the purchase, import, or transfer of Russian-origin crude oil and certain petroleum products.  Although

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the