Carlton Greene

Partner

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, 20032006
    • 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, 20032006
    • 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 | 12 min read | 06.28.24

EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG and the Transportation Sector

In response to the ongoing conflict in Ukraine and to exert further pressure on Russia, the EU enacted its 14thsanctions package against Russia on June 24, 2024. The new package comes after months of negotiations between Member States, and follow, but in many ways expand upon, those passed by the United States and the UK last week (see Crowell’s Alert on those developments here). ...

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Carlton's Insights

Client Alert | 12 min read | 06.28.24

EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG and the Transportation Sector

In response to the ongoing conflict in Ukraine and to exert further pressure on Russia, the EU enacted its 14thsanctions package against Russia on June 24, 2024. The new package comes after months of negotiations between Member States, and follow, but in many ways expand upon, those passed by the United States and the UK last week (see Crowell’s Alert on those developments here). ...