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Carlton Greene

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Areas of Focus

Overview

Clients look to Carlton for in-depth knowledge and practical, innovative solutions on sensitive economic sanctions and anti-money laundering (“AML”) matters, informed by his many years in government at the Office of Foreign Assets Control (“OFAC”), Financial Crimes Enforcement Network (“FinCEN”), and the Department of Justice (“DOJ”). Carlton Greene is the co-chair of the firm’s financial services group, and a member of its international trade and white collar and regulatory enforcement groups.

Carlton is the former chief counsel at FinCEN, the U.S. AML regulator responsible for administering the Bank Secrecy Act. Before joining FinCEN, he was an attorney-advisor at OFAC and also served as OFAC’s assistant director for transnational threats, where he directed targeting and investigations for more than 25 U.S. economic sanction programs, including those related to Iran and North Korea. In 2007, the United Nations Secretary-General appointed Carlton to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. He also previously served as a trial attorney at the DOJ, where he represented OFAC and other agencies on national security matters in federal district court litigation.

Carlton provides compliance counseling and representation in enforcement matters to global financial and non-financial companies. Based on his years of experience in government and in counseling private companies, Carlton offers valuable insights on the approaches of OFAC, FinCEN, DOJ and other agencies that assist his clients to more effectively respond to government investigations and to manage their sanctions and AML risks effectively.

Career & Education

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    • Department of the Treasury

      Chief Counsel, Financial Crimes Enforcement Network, 2014–2015
      Acting Chief Counsel, Financial Crimes Enforcement Network, 2013
      Senior Advisor to the Director, Financial Crimes Enforcement Network, 2012–2013
      Assistant Director for Transactional Threats, Office of Foreign Assets Control, 2008–2013
      Attorney-Advisor, Office of Foreign Assets Control, 2006–2007

    • United Nations
      Expert, Al-Qaida/Taliban Monitoring Team, 2007–2008
    • Department of Justice: Federal Programs Branch
      Trial Attorney, 2003–2006
    • Department of the Treasury

      Chief Counsel, Financial Crimes Enforcement Network, 2014–2015
      Acting Chief Counsel, Financial Crimes Enforcement Network, 2013
      Senior Advisor to the Director, Financial Crimes Enforcement Network, 2012–2013
      Assistant Director for Transactional Threats, Office of Foreign Assets Control, 2008–2013
      Attorney-Advisor, Office of Foreign Assets Control, 2006–2007

    • United Nations
      Expert, Al-Qaida/Taliban Monitoring Team, 2007–2008
    • Department of Justice: Federal Programs Branch
      Trial Attorney, 2003–2006

    • College of William & Mary, B.A., Philosophy, 1993
    • College of William & Mary Marshall-Wythe School of Law, J.D., 1997
    • College of William & Mary, B.A., Philosophy, 1993
    • College of William & Mary Marshall-Wythe School of Law, J.D., 1997

    • District of Columbia
    • Virginia (Inactive)
    • District of Columbia
    • Virginia (Inactive)

Carlton's Insights

Client Alert | 3 min read | 01.28.25

Supreme Court Stays Corporate Transparency Act Injunction, But Beneficial Ownership Reporting Requirements Remain Paused

On January 23, 2025, the U.S. Supreme Court granted the Government’s application for a stay of an injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop. The injunction had blocked enforcement of the CTA and implementation of the related BOI Rule, which required certain entities formed or registered to do business in the U.S. (Reporting Companies) to report information about themselves and their natural-person beneficial owners to the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department. The Supreme Court stayed the Texas Top Cop Shop injunction “pending the disposition of the [Government’s] appeal in the United States Court of Appeals for the Fifth Circuit and disposition of a petition for a writ of certiorari.” For more information on the events leading up to the Supreme Court’s review and decision to stay the injunction, please see our prior alerts here, here, and here....

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Insights

Client Alert | 3 min read | 01.28.25

Supreme Court Stays Corporate Transparency Act Injunction, But Beneficial Ownership Reporting Requirements Remain Paused

Blog Post | 01.21.25

Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions

Client Alert | 4 min read | 01.07.25

Fifth Circuit Reinstates Injunction of the Corporate Transparency Act; DOJ Petitions Supreme Court Seeking Stay of Injunction During Appeal

Client Alert | 4 min read | 12.19.24

DOJ Appeals Nationwide Preliminary Injunction of the Corporate Transparency Act, Seeks Stay of Injunction During its Appeal
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Practices

Industries

Carlton's Insights

Client Alert | 3 min read | 01.28.25

Supreme Court Stays Corporate Transparency Act Injunction, But Beneficial Ownership Reporting Requirements Remain Paused

On January 23, 2025, the U.S. Supreme Court granted the Government’s application for a stay of an injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop. The injunction had blocked enforcement of the CTA and implementation of the related BOI Rule, which required certain entities formed or registered to do business in the U.S. (Reporting Companies) to report information about themselves and their natural-person beneficial owners to the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department. The Supreme Court stayed the Texas Top Cop Shop injunction “pending the disposition of the [Government’s] appeal in the United States Court of Appeals for the Fifth Circuit and disposition of a petition for a writ of certiorari.” For more information on the events leading up to the Supreme Court’s review and decision to stay the injunction, please see our prior alerts here, here, and here....

View All Insights