Cari N. Stinebower

Practice Areas

Cari N. Stinebower is a member of Winston & Strawn’s White Collar & Government Investigations Practice in the firm's Washington, D.C. office and the Chair of the firm's International Trade Practice. 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 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.

Professional Memberships

American Bar Association (ABA) Section of Administrative Law Member

Vice Chair, Section of International Law, International Anti-Money Laundering and Professional Ethics Committee (2008–Present)

ABA Gatekeepers Task Force Member

Association of Certified Anti-Money Laundering Specialists Enterprise Member

Publications

“Bankers Worldwide: You May Not Be Interested in Export Controls, But They Are Interested in You,” Banking Law Journal, Co-Author, March 2025

“Litigation Versus the Treasury in a Post ‘Chevron Deference’ Doctrine World,” Financier Worldwide Magazine, Co-Author, Jan. 22, 2025

“Commerce Prepares for an AI Warfare Future with Quarterly Reports of AI Modeling and Computer Cluster Plans,” Global Trade & Foreign Policy Insights, Co-Author, Sept. 12, 2024

“Revised AML Program Rules Coming Soon: Federal Banking Agencies and FinCEN Propose Rules to Update AML/CFT Program Requirements,” Client Alert, Co-Author, Sept. 9, 2024

“Treasury Releases Text of Proposed Rule to Regulate Semiconductor Manufacturing, AI, and Quantum Investments in China,” Global Trade & Foreign Policy Insights, Co-Author, July 15, 2024

“June 2024 Presidential Debate: Key Policy Takeaways,” Client Alert, Co-Author, July 10, 2024

“China and Hong Kong Expand Protections Over State Secrets,” Notes From The China Desk, Co-Author, June 21, 2024

“U.S.-China Trade Update: Recent Developments in Export Controls,” Global Trade & Foreign Policy Insights, Co-Author, June 20, 2024

“China Adds Additional Entities to the Unreliable Entity List,” Global Trade & Foreign Policy Insights, Co-Author, June 11, 2024

“Do You Know Your Customer? FinCEN & SEC Propose New Investment Adviser KYC Obligations,” Client Alert, Co-Author, May 31, 2024

“The U.S. Corporate Transparency Act – Is Your Business Organization Ready to Comply?” Global Trade & Foreign Policy Insights, Co-Author, Feb. 7, 2024

“New York Governor Signs Amended Version of the LLC Transparency Act into Law,” Client Alert, Co-Author, Jan. 17, 2024

“FinCEN Launches Beneficial Ownership Information Registry,” Client Alert, Co-author, Jan. 4, 2024

“FinCEN and BIS Expand SAR Guidance for Export Control Evasion, as General Prohibition Ten Looms Large,” Global Trade & Foreign Policy Insights, Co-author, Nov. 8, 2023

“United States Eases Select Sanctions on Venezuela’s Oil Sector,” Global Trade & Foreign Policy Insights, Co-author, Oct. 20, 2023

“China Places Export Controls on Raw Materials Used in Semiconductor Manufacturing,” Global Trade & Foreign Policy Insights, Co-author, July 9, 2023

“The EU Issues an Eleventh Package of Sanctions Against Russia,” Global Trade & Foreign Policy Insights, Co-author, June 26, 2023

“U.S. Sanctions and Export Controls Against Russia and FinCEN Alert,” Global Trade & Foreign Policy Insights, Co-author, May 25, 2023

“The EU Issues a Tenth Package of Sanctions Against Russia,” Global Trade & Foreign Policy Insights, Co-author, March 2, 2023

“The United States and the United Kingdom Announce New Wave of Sanctions Against Russia,” Global Trade & Foreign Policy Insights, Co-author, March 2, 2023

“Winston & Strawn’s International Trade Overview of U.S., EU, and Japanese Sanctions: One Year After Russia’s Invasion of Ukraine,” Global Trade & Foreign Policy Insights, Co-author, Feb. 23, 2023

“China Adds Lockheed Martin and Raytheon Missiles & Defense to the Unreliable Entity List,” Global Trade & Foreign Policy Insights, Co-author, Feb. 17, 2023

“U.S. arrests Bitzlato cofounder, alleges $700 mln of illicit funds processed,” Reuters, Media Mention, Jan. 18, 2023

“Venezuelan oil exports flow using false documents, ships linked to Iran,” Reuters, Media Mention, Nov. 30, 2022

“Removing Sanctions on Crypto Mixer Tornado Cash Won’t Be Easy,” The Wall Street Journal – Risk & Compliance Journal, Media Mention, Oct. 27, 2022

“Top 12 Importing Do’s and Don’ts,” Inbound Logistics, Media Mention, Oct. 18, 2022

“Unpacking OFAC’s New Russian Accounting Services Ban,” Law360, Co-author, May 16, 2022

“How Multinationals Can Withstand US-China Trade Conflicts,” Law360, Co-author, March 16, 2022

“Gazprombank: The Big Russian Lender That Dodged Western Sanctions,” The Wall Street Journal, Media Mention, March 11, 2022

“Biden aims to hit wealthy Russians where it hurts to stop war against Ukraine,” Washington Examiner, Media Mention, March 3, 2022

“Worst-Ever Russia Sanctions Set To Become A Business, Market Nightmare,” Today UK News and UK Time News, Media Mention, March 1, 2022

“Higher prices, more risk: How Russia’s war on Ukraine is likely to affect the global economy,” NPR’s Marketplace Podcast, Media Mention, Feb. 24, 2022

“Law firms gear up as U.S., Europe impose new sanctions on Russia,” Reuters, Media Mention, Feb. 23, 2022

“Balance of Power: Preparing for Sanctions,” Bloomberg Balance of Power Podcast, Media Mention, Feb. 18, 2022

“The Week in GRC: US and European Activist Investors Eye UK Companies and Kohl’s Adopts Poison Pill,” Corporate Secretary, Media Mention, Feb. 4, 2022

“Threat of Hard-Hitting Russia Sanctions Leaves U.S. Companies Planning for All Scenarios,” The Wall Street Journal – Risk & Compliance Journal, Media Mention, Jan. 31, 2022

“The Morning Risk Report: Afghanistan Sanctions Could Be Imposed but Carry Risks, Observers Say,” The Wall Street Journal – Risk & Compliance Journal, Media Mention, Aug. 17, 2021

“Trump Order Clarifies Chinese Company Ban, but Questions Linger,” The Wall Street Journal – Risk & Compliance Journal, Media Mention, Jan. 14, 2021

“Deutsche’s Compliance Procedures Limit Damage of Sanctions Settlement,” The Wall Street Journal – Risk & Compliance Journal, Media Mention, Sept. 10, 2020

“Commerce Move Affects Exports To Chinese Nuclear Co.,” Law360, Co-author, Sept. 17, 2019

“OFAC Places Caps on Remittances to Cuba and Removes Authorization for ‘U-Turn’ Transactions,” Winston & Strawn Briefing, Co-author, Sept. 11, 2019

“Helms-Burton litigation adds a wrinkle to business ventures in Cuba,” WorldECR Special Report: US Sanctions and Enforcement, Issue 81, Co-author, July/Aug. 2019

Personal

Recognized in several directories and publications, including:

Chambers Global for International Trade: Export Controls & Economic Sanctions – USA (2019–2025)

Chambers USA for International Trade: Export Controls & Economic Sanctions (2018–2024)

The Legal 500 US: “Firm to Watch”, International Trade: Customs, Export Controls and Economic Sanctions (2023–2024)

The Legal 500 US: “Key Lawyer” for Transport: Aviation and Air Travel – Finance (2021–2023) and Dispute Resolution: Corporate and White-Collar Criminal Defense (2024)

The Legal 500 Latin America International Firms: for Compliance & Investigations (2024-2025)

Latin Lawyer 250: Recognized for Arbitration (2024)

Who’s Who Legal: Trade & Customs (2024)

Lawdragon: “500 Leading Global Litigators” for International Arbitration & Litigation (esp. Global Trade) (2024) and “100 Lawyers You Need to Know in South America” for International Trade, Regulations, and Investigations

Latinvex: “Top 100 Female Lawyers” for Anti-corruption (2018–2024)

Law360: “MVP” for International Trade (2020)

The National Law Journal: “Government Relations Trailblazer” (2019)