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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 | 2 min read | 02.07.25

Federal Government Appeals Order Blocking Enforcement of the CTA’s Beneficial Ownership Information Rule and Seeks Stay Pending Appeal, but Fate of CTA Remains Unclear

As we have previously reported, enforcement of the Corporate Transparency Act’s (the CTA) Beneficial Ownership Information Reporting rule (the BOI Rule) remains blocked nationwide as the result of an order from the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of the Treasury. On January 7, 2025, the Smith court granted a motion for preliminary injunction enjoining enforcement of the CTA against the named plaintiffs and their related entities, while also issuing a nationwide stay of the effective date of the BOI Rule. This occurred before the Supreme Court stayed a separate nationwide injunction of the CTA and stay of the BOI Rule in Texas Top Cop Shop v. McHenry....

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Insights

Client Alert | 2 min read | 02.07.25

Federal Government Appeals Order Blocking Enforcement of the CTA’s Beneficial Ownership Information Rule and Seeks Stay Pending Appeal, but Fate of CTA Remains Unclear

Client Alert | 6 min read | 02.07.25

“Maximum Pressure” on Iran Is Back: What This Means for Sanctions and Export Controls

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
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Practices

Industries

Carlton's Insights

Client Alert | 2 min read | 02.07.25

Federal Government Appeals Order Blocking Enforcement of the CTA’s Beneficial Ownership Information Rule and Seeks Stay Pending Appeal, but Fate of CTA Remains Unclear

As we have previously reported, enforcement of the Corporate Transparency Act’s (the CTA) Beneficial Ownership Information Reporting rule (the BOI Rule) remains blocked nationwide as the result of an order from the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of the Treasury. On January 7, 2025, the Smith court granted a motion for preliminary injunction enjoining enforcement of the CTA against the named plaintiffs and their related entities, while also issuing a nationwide stay of the effective date of the BOI Rule. This occurred before the Supreme Court stayed a separate nationwide injunction of the CTA and stay of the BOI Rule in Texas Top Cop Shop v. McHenry....

View All Insights