Professionals

Cari Stinebower

Partner

Chair, International Trade Practice

Overview
Experience
Credentials
Insights & News

Cari practices in the area of economic sanctions, export controls, and anti-money laundering (AML). With more than twenty-five years of government and private sector experience, she counsels clients on how to navigate the complex—and sometimes conflicting—web of government regulations. Cari provides practical guidance designed to allow clients to respond in a complex and changing political and business environment. Together with Winston’s other practices, she provides comprehensive and practical solutions for a wide range of clients.

Cari works closely with colleagues in the Global Privacy & Data Security, Financial Services, Corporate, and Complex Commercial Litigation practices.

Cari counsels clients on compliance with U.S. economic sanctions, Bank Secrecy Act and AML laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. She works with financial institutions and multinational corporations to develop compliance programs, conduct AML and Office of Foreign Assets Control (OFAC) risk assessments, conduct internal investigations, respond to government investigations, and address potential conflicts of law arising from non-U.S. data privacy and “blocking” laws and regulations. In the last five years, she also has worked closely with all aspects of the maritime sector to address compliance with U.S. sanctions targeting Iran and, more recently, to address compliance with the Russian Price Cap Coalition.

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 and 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. She has been quoted in publications such as The Wall Street Journal, The New Yorker, Reuters, Bloomberg and MoneyLaundering.com. Cari also served on Law360’s 2022 International Trade Editorial Advisory Board.

Cari has been a guest lecturer at Yale University, Georgetown Law School, and the University of Zurich.

Key Matters

Some of the experience represented below may have been handled at a previous firm.

Government Experience

U.S. Department of the Treasury – Attorney Advisor, Office of the General Counsel, Office of Foreign Assets Control (2001–2005)
Office of International Programs, Office of Foreign Assets Control (1999–2001)

Representative Experience

Represents numerous maritime industry participants in establishing state-of-the-art compliance programs designed to nimbly react to the fast-paced designations – both multilateral and unilateral. Engagement includes coordination with federal agencies.
Worked with a Middle Eastern financial regulator to establish and review anti-money laundering and sanctions compliance requirements for foreign financial institutions operating in that jurisdiction.
Represented a European financial institution in a multiple-agency investigation into sanctions and money laundering violations relating to avoiding Iran sanctions.
Worked with a U.S. manufacturer to maintain risk-based sanctions and an export controls compliance program, addressing EU and Canadian blocking statutes.
Worked with non-U.S. insurers and reinsurers to address rapidly evolving sanctions compliance obligations stemming from the termination of U.S. involvement in the Joint Comprehensive Plan of Action.
Together with a U.S. heavy equipment manufacturer, addressed evolving sanctions on Venezuela, incorporating anti-money laundering and anti-corruption compliance; applying for license applications from the Office of Foreign Assets Control (OFAC) to wind down obligations in Venezuela.
Represents multiple clients before OFAC and State in de-listing matters. Representation can and has included litigation before the DC Circuit to challenge sanctions designations.
Navigated primary and secondary sanctions exposure risk for a non-U.S. client engaged in the acquisition of equipment where Russian banks were involved in financing.

Recent Experience

Arthur J. Gallagher Acquisition of Clements Worldwide

Crowe LLP's Carveout Sale of its Health Care Consulting Business

Culper Capital Partners's Acquisition of Ring Precision Components, New Vision Industries, and Dieco to form The Producto Group

Dominion Financial Services: Mortgage-Backed Notes Series 2021-1

Terold Acquisition of Majority Stake in WX Brands

Hudson Ferry Capital's Sale of ALCOM

Forum Merger II Corp. Business Combination with Ittella International, Inc.

Argand Partners Acquires Cherry

US$400M GATX Corporation Senior Notes Offering

Capabilities

Government Investigations, Enforcement & Compliance

Compliance Programs

International Trade

Corporate Governance

Financial Services Transactions & Regulatory

Financial Services Litigation

Maritime & Admiralty

Financial Services

Cryptocurrencies, Digital Assets & Blockchain Technology

Automotive & Mobility

Oil & Gas

Energy

Technology, Media & Telecommunications

Insurance

Financial Crimes Compliance

Key Matters

Some of the experience represented below may have been handled at a previous firm.

Government Experience

U.S. Department of the Treasury – Attorney Advisor, Office of the General Counsel, Office of Foreign Assets Control (2001–2005)
Office of International Programs, Office of Foreign Assets Control (1999–2001)

Representative Experience

Represents numerous maritime industry participants in establishing state-of-the-art compliance programs designed to nimbly react to the fast-paced designations – both multilateral and unilateral. Engagement includes coordination with federal agencies.
Worked with a Middle Eastern financial regulator to establish and review anti-money laundering and sanctions compliance requirements for foreign financial institutions operating in that jurisdiction.
Represented a European financial institution in a multiple-agency investigation into sanctions and money laundering violations relating to avoiding Iran sanctions.
Worked with a U.S. manufacturer to maintain risk-based sanctions and an export controls compliance program, addressing EU and Canadian blocking statutes.
Worked with non-U.S. insurers and reinsurers to address rapidly evolving sanctions compliance obligations stemming from the termination of U.S. involvement in the Joint Comprehensive Plan of Action.
Together with a U.S. heavy equipment manufacturer, addressed evolving sanctions on Venezuela, incorporating anti-money laundering and anti-corruption compliance; applying for license applications from the Office of Foreign Assets Control (OFAC) to wind down obligations in Venezuela.
Represents multiple clients before OFAC and State in de-listing matters. Representation can and has included litigation before the DC Circuit to challenge sanctions designations.
Navigated primary and secondary sanctions exposure risk for a non-U.S. client engaged in the acquisition of equipment where Russian banks were involved in financing.