- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border.
- OFAC’s actions are the latest examples of a broader
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 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.
Firewall Up: FCC Bars Foreign-Made Routers in New Covered List Update
On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of…
Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela
Introduction
Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela…
Treasury Seeks Public Input on CFIUS Known Investor Program and Streamlining of Foreign Investment Reviews
On February 9, 2026, the U.S. Department of the Treasury’s (Treasury) Office of Investment Security (OIS) published a request for information (RFI) seeking public comments on how the Committee on Foreign Investment in the United States (CFIUS) might streamline its foreign investment review process, including through the Known Investor Program (KIP). The RFI requests feedback…
OFAC Fines U.S. Private Equity Fund for Russian Sanctions Violations
On December 2, 2025, OFAC announced an ~$11 million penalty settlement with IPI Partners, LLC (“IPI”), a Chicago-based U.S. private equity fund, to settle its civil liability for 51 potential violations of OFAC’s Russia sanctions. The enforcement action underscores the importance of diligence to guard against potential sanctions violations. In brief, OFAC found that IPI…
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those…
Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case
On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement…
Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System
Reflecting the administration’s continued focus on transnational cartels, on June 25, 2025, FinCEN identified three Mexican financial institutions as “primary money laundering concerns,” and imposed restrictions on U.S. financial institutions from engaging in transactions with these entities.
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U.S. Department of the Treasury to Establish Fast Track CFIUS Process for Foreign Investors
On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will establish a fast track review process to facilitate greater investment in the United States from ally and partner sources. Specifically, Treasury stated that the new fast track Committee on Foreign Investment in the United States (CFIUS) review process will include…
Client Alert: CFIUS Finalizes Regulations to Increase Penalties, Expand Subpoena Authority, and Enhance Enforcement Authorities to Protect National Security
On Monday, November 18, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced that it had finalized the regulatory changes previewed in April pertaining to penalties for violations of statutory or regulatory provisions or agreements, conditions, or orders issued pursuant thereto; negotiation of mitigation agreements; requests for information by…