Caroline E. Brown

Partner

Overview

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar and 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.

Most recently, she served as an Attorney-Advisor in the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), where she developed an in-depth understanding of AML regulation and enforcement and FinCEN’s role in guarding the U.S. financial system against money laundering and terrorist financing. Before joining FinCEN, she served as an attorney in the Treasury Department’s Office of General Counsel, Enforcement and Intelligence, which provides counsel to the Undersecretary for Terrorism and Financial Intelligence. There, Caroline advised on sanctions, AML, and various other national security issues relevant to the nation’s financial system.

While at DOJ, Caroline was detailed to the White House for a year, where she coordinated communications strategy focused on national security. She previously worked on the 2008 Obama Presidential Campaign and served on the Obama Presidential Transition Team from 2008 to 2009. Her time at the White House as well as at Treasury and DOJ has given her significant experience managing rapid response and crisis communications.

Caroline’s time in government has enabled her to build strong relationships at senior levels across a number of U.S. government agencies, including DOJ, the FBI, the National Intelligence Council and other components of the Intelligence Community, the FCC, and the Departments of Defense, Homeland Security, State, Energy, Commerce, and the Treasury.

Caroline began her legal career as a law clerk for the Honorable Jon McCalla in the U.S. District Court for the Western District of Tennessee before joining the litigation group of a global law firm in Washington, D.C. She is a life member of the Council on Foreign Relations, a National Security Fellow at the Foundation for the Defense of Democracies, an Aspen Institute Socrates Scholar, and a Young Leader of the transatlantic organization Atlantik-Brucke.   

Career & Education

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    • Department of the Treasury
      Attorney-Advisor, Office of the General Counsel, Enforcement and Intelligence, 2015–2019
      Attorney-Advisor, Financial Crimes Enforcement Network, 2009–2014
    • The White House
      Detailed from DOJ to the White House Office of Communications, 2010–2011
    • Department of Justice: National Security Division
      Attorney-Advisor, 2009–2015
    • Department of the Treasury
      Attorney-Advisor, Office of the General Counsel, Enforcement and Intelligence, 2015–2019
      Attorney-Advisor, Financial Crimes Enforcement Network, 2009–2014
    • The White House
      Detailed from DOJ to the White House Office of Communications, 2010–2011
    • Department of Justice: National Security Division
      Attorney-Advisor, 2009–2015
    • Duke University, B.A., 1998
    • University of Michigan Law School, J.D., 2002
    • Duke University, B.A., 1998
    • University of Michigan Law School, J.D., 2002
    • District of Columbia
    • New York
    • District of Columbia
    • New York
  • Professional Activities and Memberships

    • Council on Foreign Relations, Life Member
    • National Security Fellow, Foundation for the Defense of Democracies
    • Socrates Scholar, Aspen Institute
    • Atlantik-Brucke

    Professional Activities and Memberships

    • Council on Foreign Relations, Life Member
    • National Security Fellow, Foundation for the Defense of Democracies
    • Socrates Scholar, Aspen Institute
    • Atlantik-Brucke

Caroline's Insights

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

As we discussed in our recent client alert, the U.S. District Court for the Eastern District of Texas issued an opinion and order on December 3, 2024, ("the Order") enjoining the federal government from enforcing the CTA and a rule implementing it. The rule requires certain entities formed or registered to do business in the U.S. ("reporting companies") to report information about themselves and their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury....

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Caroline's Insights

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

As we discussed in our recent client alert, the U.S. District Court for the Eastern District of Texas issued an opinion and order on December 3, 2024, ("the Order") enjoining the federal government from enforcing the CTA and a rule implementing it. The rule requires certain entities formed or registered to do business in the U.S. ("reporting companies") to report information about themselves and their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury....