Cari N. Stinebower is a member of the Crowell & Moring's International Trade practice group in the firm's Washington, D.C. office.
Cari counsels clients on compliance with U.S. economic sanctions, FinCEN's Bank Secrecy Act Regulations, the Foreign Corrupt Practices Act (FCPA), and export controls. She works with financial institutions to develop compliance programs, conduct anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) risk assessments, conduct internal investigations, and respond to government investigations. Cari often works with multinational corporations to navigate the complex web of U.S. sanctions, money laundering laws and regulations, and export controls that can implicate virtually any U.S. dollar denominated transaction. She also works with industry groups to develop sanctions and AML best practices policies and procedures.
Cari served as counsel for the U.S. Department of the Treasury's OFAC and as a Programs Officer for OFAC, where she advised on sanctions and anti-terrorism legislation, drafted United Nations Security Council Resolutions and related executive orders. Cari acted as agency counsel in Treasury's defense of a number of challenges to OFAC's authority, whether in litigation related to enforcement actions or in response to congressional investigations. As a result of her work at Treasury, Cari received the Secretary of the Treasury's Certificate for her role in providing guidance in the war against terrorism, establishing a program targeting the Taliban, working with the interagency group to unwind the first sanctions targeting the government of Libya, and drafting the Foreign Narcotics Kingpin Designation Act.
Cari is a frequent writer and speaker on sanctions, AML and anti-corruption/anti-bribery related issues and has been quoted in publications such as the Wall Street Journal, the New Yorker and MoneyLaundering.com.
She is a member of the American Bar Association's Gatekeepers' Task Force and a vice-chair of the ABA's Anti-Money Laundering subcommittee. Cari has been a guest lecturer at the George Mason School of Law.
Cari received her B.A. from Amherst College (1993), J.D. from American University's Washington College of Law (1996) and Masters from American University (1996).
Affiliations
Memberships
· American Bar Association (ABA), Section of Administrative Law
· Vice-Chair, Section of International Law, International Anti-Money Laundering and Professional Ethics Committee (2008 - Present)
· ABA Gatekeepers Task Force
· Republican National Lawyers Association (RNLA)
Publications
· "Global Trade Compliance for International Socially Responsible Investment," Law for Change (June 16, 2011). Co-author: Cari N. Stinebower.
· "Updating Compliance Procedures to Incorporate the UK Bribery Act," The Metropolitan Corporate Counsel, Vol. 19, No. 3 (March 2011). Co-author: Cari N. Stinebower.
· "FCPA Enforcement Focus: Pharmaceutical Companies," The Metropolitan Corporate Counsel, Vol. 18 No. 6 (June 2010). Author: Cari N. Stinebower.
· "Export Controls and Economic Sanctions," The International Lawyer, Vol. 44, No. 1 (Spring 2010). Co-Authors: Cari N. Stinebower, John W. Boscariol, J. Patrick Briscoe, Laura el-Sabaawi, Steven C Emme, Jahn M. Hartwig, Jack R. Hayes, Adam Klauder, Carlos Ramos-Mrosovsky, and Petra A Vorwig.
· "U.S. and International Anti-Money Laundering Developments," The International Lawyer, Vol. 43, No. 2 (Summer 2009). Co-Author: Cari N. Stinebower.
· "New OFAC Enforcement Guidelines," The Metropolitan Corporate Counsel, Vol. 16 No. 11 (November 2008). Co-Authors: Cari N. Stinebower, John B Reynolds III and Amy Worlton.
· "Time Kills Deals: Getting international aircraft buyers to say 'Yes', 'Dah', 'Si', 'Shi' and 'Hai'," World Aircraft Sales Magazine (October 2008). Co-Authors: Cari N. Stinebower, Gregory Cirillo and Gary Horowitz.
· "New Regulations Concerning Foreign Correspondent and Private Banking Accounts, and Proposed Rules for Enhanced Due Diligence for Certain Non-U.S. Banks," Privacy and Data Security Law Journal (April 2006). Co-Authors: Cari N. Stinebower, John B Reynolds III and Amy Worlton.
Alerts & Newsletters
· "A First Step or an Empty Gesture: Relaxing Sanctions against Burma/Myanmar?," International Trade Bulletin (April 19, 2012). Contacts: Cari N. Stinebower, Paul Davies, David Wolff, Andrew Blasi.
· "Potential for Change in Anti-Money Laundering Laws & Regulations: New FATF Recommendations, FinCEN Calls for Comments on Customer Due Diligence Procedures," White Collar Alert (March 8, 2012). Contacts: Cari N. Stinebower, Caitlin FitzRandolph Bos, Linda Lerner, Eden L. Rohrer.
· "This Month In International Trade - February 2012," International Trade Bulletin (March 7, 2012). Contacts: John B. Brew, Alan W. H. Gourley, Daniel Cannistra, Carrie F. Fletcher, Alexander H. Schaefer, Cari N. Stinebower, Jini Koh, James (J.J.) Saulino, David Wolff, Michael Larmoyeux.
· "This Month In International Trade - January 2012," (February 8, 2012). Contacts: Laurent Ruessmann, Kristof Roox, Michael J. Songer, John B. Brew, Alexander H. Schaefer, Cari N. Stinebower, Jini Koh, Elena Klonitskaya, Francesca Condello, David Wolff, Michael Larmoyeux.
· "Congress Readies Its Cudgel: Expansive New Iran Sanctions Advance Through The Senate," (February 6, 2012). Contacts: Alan W. H. Gourley, Cari N. Stinebower, Carrie F. Fletcher, David Wolff.
· "Recent Developments In EU Export Controls And Sanctions," (January 31, 2012). Contacts: Laurent Ruessmann, Elena Klonitskaya, Cari N. Stinebower, David Wolff.
Speaking Engagements
· "The OFAC Licensing Process, Timeline and Criteria: How to Work with OFAC to Expedite Approvals," ACI's OFAC Bootcamp (December 2, 2011). Speaker: Cari N. Stinebower.
· "OFAC Enforcement Trends: Lessons Learned & the Road Ahead," West Professional Development Webinar (November 29, 2011). Speaker: Cari N. Stinebower.
· "Promoting New Sudan Accountability and Reinvestment Act for 2011," The National Policy Alliance 2011 Leadership Meeting (September 20, 2011). Speaker: Cari N. Stinebower.
· "OFAC Compliance: Legal and Ethical Responsibilities," CT Corporation 2011 Seminar Series (August 17, 2011). Speaker: Cari N. Stinebower.
· "ACI's National Forum on AML and OFAC Compliance for the Insurance Industry," (January 20-21, 2011). Co-Chair: Cari N. Stinebower.
· "Sanctions: Developing and Implementing Policies and Procedures to Ensure Compliance with State and Federal Mandates," ACI's National Forum on AML and OFAC Compliance for the Insurance Industry (January 20, 2011). Speaker: Cari N. Stinebower.
· The Cost of Non-Compliance: What Recent Cases and Penalty Levels Reveal About OFAC's Priorities and Enforcement Approach," ACI's OFAC Boot Camp (December 9, 2010). Speaker: Cari N. Stinebower.
· "The Foreign Corrupt Practices Act and Anti-Money Laundering," ILI's Orientation in the U.S. Legal System (July 28, 2010). Speaker: Cari N. Stinebower.
· "Evolving Compliance Requirements and Ethical Considerations for the Business Law Attorney," CT Corporation's 2010 Seminar Series (June 17, 2010). Speaker: Cari N. Stinebower.
· "Complying with Tightened International Sanctions against Iran: What You Can Do and What You Can't Do," ACI OFAC Enforcement & Compliance (April 29-30, 2010). Panelist: Cari N. Stinebower.
· "Report and Recommendation on Voluntary Guidance on AML for Lawyers," The ABA's Section of International Law Council Meeting (April 17, 2010). Speaker: Cari N. Stinebower.
· "Preventing Federal Intrusion into State Supreme Court Regulation of Lawyers," ABA Midyear Meeting 2010 (February 4, 2010). Panelist: Cari N. Stinebower.
· "Foreign Corrupt Practices Act: How New Enforcement Will Impact Your Business," Foreign Corrupt Practices Act Webinar (January 26, 2010). Speaker: Cari N. Stinebower.
· "Tailoring Your AML Program to Comply with the Foreign Corrupt Practices Act," Association of Certified Anti-Money Laundering Specialists Webinar (November 18, 2009). Speaker: Cari N. Stinebower.
· "Due Diligence in Government Contractor Mergers and Acquisitions," Federal Publications Seminars (October 28-29, 2009). Speaker: Cari N. Stinebower.
· "Corporate Transparency and Other International Issues," 21st Annual ABA Money Laundering Enforcement Conference (October 11, 2009). Speaker: Cari N. Stinebower.
· "How Well Do You Know Your Client?," 2009 CTLA Annual Conference (October 1-3, 2009). Speaker: Cari N. Stinebower.
· "Terrorism and the Corporation: Ethical Implications for Officers, Directors and Their Counsel," Seattle University School of Law: The Annual James L. Holman Ethics Program (April 3, 2009). Speaker: Cari N. Stinebower.
· "U.S. Embargoes and Economic Sanctions Law: Recent Developments Involving Iran, Cuba, Sudan and "Specially Designated Nationals"," 2008 ABA Annual Meeting (August 10, 2008). Speaker: Cari N. Stinebower.