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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.

On November 13, 2025, the U.S. Department of the Treasury’s (“Treasury’s”) Financial Crimes Enforcement Network (“FinCEN”) issued a finding (“Finding”) and related notice of proposed rulemaking (“Proposed Rule”) pursuant to Section 311 of the USA PATRIOT Act (“Section 311”), targeting ten Mexico-based gambling establishments (“Gambling Establishments”).  FinCEN found transactions involving the Gambling Establishments to constitute a “class of transactions” of “primary money-laundering concern” for purposes of Section 311.  In particular, FinCEN found that the Gambling Establishments ultimately were controlled by a criminal group that used the establishments to facilitate money laundering for the Sinaloa Cartel.

Continue Reading Treasury Continues Focus on Cartels: Understanding FinCEN’s Latest Action Restricting Transactions with Certain Mexico-Based Gambling Establishments

On August 17, 2023, the U.S. District Court for the Western District of Texas granted summary judgment to the U.S. Department of the Treasury (Treasury) on all of the plaintiffs’ claims in the lawsuit challenging the Department’s Treasury’s Office of Foreign Assets Control’s (OFAC) designation of Tornado Cash, a purportedly decentralized cryptocurrency mixer that runs

On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group