Provided by Cari N. Stinebower
Cari N. Stinebower is a member of Winston & Strawn’s White Collar, Regulatory Defense & Investigations Practice in the firm's Washington, D.C. office. She also works closely with colleagues in the Global Privacy & Data Security Practice, Financial Services, Corporate, and Complex Commercial Litigation groups.
Cari counsels clients on compliance with U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. She works with financial institutions and multi-national 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. Cari 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, Reuters, Bloomberg and MoneyLaundering.com. Cari also serves on Law360’s 2022 International Trade Editorial Advisory Board.
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 Yale University, Georgetown Law School, and the University of Zurich.
Cari Stinebower, based in the Washington, D.C. office, practices in the area of economic sanctions, export controls, and anti-money laundering. With over twenty years of government and private sector experience, Cari 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.
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
Media Mention, “U.S. arrests Bitzlato cofounder, alleges $700 mln of illicit funds processed,” Reuters, January 18, 2023
Media Mention, “Venezuelan oil exports flow using false documents, ships linked to Iran,” Reuters, November 30, 2022
Media Mention, “Removing Sanctions on Crypto Mixer Tornado Cash Won’t Be Easy,” The Wall Street Journal, Risk & Compliance Journal, October 27, 2022
Media Mention, “Top 12 Importing Do's and Don'ts,” Inbound Logistics, October 18, 2022
Co-author, “Unpacking OFAC's New Russian Accounting Services Ban,” Law360, May 16, 2022
Co-author, “How Multinationals Can Withstand US-China Trade Conflicts,” Law360, March 16, 2022
Media Mention, “Gazprombank: The Big Russian Lender That Dodged Western Sanctions,” The Wall Street Journal, March 11, 2022
Media Mention, “Biden aims to hit wealthy Russians where it hurts to stop war against Ukraine,” Washington Examiner, March 3, 2022
Media Mention, “Worst-Ever Russia Sanctions Set To Become A Business, Market Nightmare,” Today UK News and UK Time News, March 1, 2022
Media Mention, “Higher prices, more risk: How Russia's war on Ukraine is likely to affect the global economy,” NPR’s Marketplace Podcast, February 24, 2022
Media Mention, “Law firms gear up as U.S., Europe impose new sanctions on Russia,” Reuters, February 23, 2022
Media Mention, “Balance of Power: Preparing for Sanctions,” Bloomberg Balance of Power Podcast, February 18, 2022
Media Mention, “The week in GRC: US and European activist investors eye UK companies and Kohl’s adopts poison pill,” Corporate Secretary, February 4, 2022
Media Mention, “Threat of Hard-Hitting Russia Sanctions Leaves U.S. Companies Planning for All Scenarios,” Wall Street Journal, Risk & Compliance Journal, January 31, 2022
Media Mention, “The Morning Risk Report: Afghanistan Sanctions Could Be Imposed but Carry Risks, Observers Say,” Wall Street Journal, Risk & Compliance Journal, August 17, 2021
Media Mention, “Trump Order Clarifies Chinese Company Ban, but Questions Linger,” Wall Street Journal, Risk & Compliance Journal, January 14, 2021
Media Mention, “Deutsche’s Compliance Procedures Limit Damage of Sanctions Settlement,” Wall Street Journal, Risk & Compliance Journal, September 10, 2020
Recognized as a “Key Lawyer” by The Legal 500 U.S. (2021-2022), Transport: Aviation and Air Travel- Finance
Named a 2020 Law360 MVP in the International Trade category
Named a 2019 Government Relations Trailblazer by the National Law Journal
Ranked in Chambers USA 2018-2022, International Trade: Export Controls & Economic Sanctions
Ranked in Chambers Global 2019-2023, International Trade: Export Controls & Economic Sanctions – USA
Recognized in The Legal 500 United States 2022, Firms to Watch: International Trade
Ranked by The Legal 500 in the International Trade category for her sanctions and anti-corruption work
Ranked by The Legal 500 Latin America: International Firms – Recognized Lawyer for Compliance & Investigations
Ranked as Top 100 Female Lawyers in Latinvex 2018-2022 for her anti-corruption work
Working with Middle Eastern Financial Regulator to establish and review anti-money laundering and sanctions compliance requirements for foreign financial institutions operating in that jurisdiction.
Represented European financial institution in multiple-agency investigation into sanctions and money laundering violations relating to avoiding Iran sanctions.
Work with U.S. manufacturer to maintain risk-based sanctions and export controls compliance program, addressing EU and Canadian blocking statutes.
Work with non-U.S. insurers and reinsurers to address rapidly evolving sanctions compliance obligations stemming from termination of U.S. involvement in the Joint Comprehensive Plan of Action.
Together with U.S. heavy equipment manufacturer, address evolving sanctions on Venezuela, incorporating anti-money laundering and anti-corruption compliance; apply for license applications from OFAC to wind down obligations in Venezuela.
Represent client before OFAC in filing a de-listing petition.
Navigate primary and secondary sanctions exposure risk for non-U.S. client engaged in acquisition of equipment where Russian banks are involved in financing.
Industry Sector Expertise
White Collar, Regulatory Defense & Investigations
Financial Services Regulatory / Compliance
International Trade, CFIUS, Customs, Export Controls & Sanctions
Digital Assets & Blockchain Technology
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District of Columbia
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