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.
Honors and Awards
- Recognized as a “Key Lawyer” by The Legal 500 U.S. (2021), 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 2018-2021, International Trade: Export Controls & Economic Sanctions
- Ranked in Chambers Global 2019-2022, International Trade: Export Controls & Economic Sanctions – USA
- 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 2018-2021 for her anti-corruption work
Memberships and professional activities:
- 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
Some of the experience represented below may have been handled at a previous firm.
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)
- 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.
- Culper Capital Partners Acquisition of Ring Precision Components, New Vision Industries & Dieco to form The Producto Group
- Dominion Financial Services: Mortgage-Backed Notes Series 2021-1
- Project Crush - WX Brands
- Hudson Ferry Capital Sale of ALCOM
- Forum Merger II Corp. Business Combination with Ittella International, Inc.
- Argand Partners Acquires Cherry
- 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, “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, “Law Firms Gear Up for Potentially Unprecedented Sanctions if Russia Invades Ukraine,” Reuters, Legal News, February 4, 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
- Co-author, “Commerce Move Affects Exports To Chinese Nuclear Co.,” Law360, September 17, 2019
- Co-author, “OFAC Places Caps on Remittances to Cuba and Removes Authorization for “U-Turn” Transactions,” Winston & Strawn Briefing, September 11, 2019
- Co-author, “Helms-Burton litigation adds a wrinkle to business ventures in Cuba,” WorldECR Special Report: US Sanctions and Enforcement, Issue 81, July/August 2019
- Co-author, “Banks Beware: A Second Round of Significant Extraterritorial Sanctions Looms,” Winston & Strawn Briefing, July 12, 2019
- Co-author, “In Two Announcements, OFAC Amends Three General Licenses Relating to Venezuelan and Ukrainian Transactions and Makes Minor Amendments to the North Korean Sanctions Regulations,” Winston & Strawn Briefing, July 1, 2019
- Co-author, “U.S. Government Pressures Iran’s Leadership with Additional Sanctions,” Winston & Strawn Briefing, June 26, 2019
- Co-author, “Five Chinese Entities Involved with Supercomputers Placed on Entity List,” Winston & Strawn Briefing, June 26, 2019
- Co-author, “Regulatory Amendments to 31 C.F.R. Part 501: Reporting, Procedures, and Penalties Regulations,” Winston & Strawn Briefing, June 21, 2019
- Co-author, “Commerce and Treasury Narrow Travel General Licenses to Cuba,” Winston & Strawn Briefing, June 5, 2019
- Co-author, “BIS Issues 90-DAY Temporary General License Authorizing Certain Exports to Huawei,” Winston & Strawn Briefing, May 23, 2019
- Co-author, “Developments in Telecom Supply Chain Security Controls,” Winston & Strawn Briefing, May 17, 2019
- Co-author, “DOJ Issues Updated Guidance on the “Evaluation of Corporate Compliance Programs,” Winston & Strawn Briefing, May 13, 2019
- Co-author, “Developments in U.S. Policy Toward Iran: New Executive Order Targets the Iron, Steel, Aluminum, and Copper Sectors of Iran,” Winston & Strawn Briefing, May 10, 2019
- Co-author, “Lifting of Helms-Burton Title III Waiver and Sanctions on Cuba, Venezuela, Iran, and Nicaragua,” Winston & Strawn Briefing, April 24, 2019
- Co-author, “All or Nothing? OFAC Adds PDVSA to the SDN List," International Trade Bulletin, January 30, 2019
- Co-author, “The Month in International Trade – December 2018," International Trade Bulletin, January 10, 2019
- Co-author, “Iran: Sanctions Issues Facing The International Shipping and Insurance Industries," World ECR A World of Change, November 2018
- Co-author, “Financial Regulators Have Gotten the Memo – The Brand ‘Memo’," SA Financial Regulation Journal, September 21, 2018
- Author for AML Chapter, Handbook of Export Controls and Economic Sanctions, 2013
- Co-author, American Bar Association, International Legal Developments Year in Review: 2009. Chapter 2: Export Controls and Economic Sanctions, Spring 2010
- Co-panelist, “International Trade: 2021 Year End Review and Predictions for 2022,” Winston & Strawn Webinar, January 20, 2022
- Co-panelist, “Iran: What to Expect from Current Iran Negotiations and Will Opportunities Open in 2022?” American Conference Institute U.S. Economic Sanctions Enforcement and Compliance Conference, December 7, 2021
- Co-panelist, “China Landscape: Staying Compliant with Rapidly Changing Export Controls and Sanctions Regulations,” American Conference Institute, April 27, 2021
- Co-panelist, “Trade, National Security and the Future of US-China Economic Relations,” NFTC's 2021 Virtual Conference and Awards Ceremony, January 12, 2021
- Co-panelist, “Changing Hands: International Trade Under a New Administration,” Winston & Strawn Webinar, December 17, 2020
- Co-panelist, “Economic Sanctions 2021: What to Expect from the New Administration,” ACAMS U.S. Capital Chapter Panel, November 13, 2020
- Presenter, “The Moving Target of Sanctions Compliance,” First Risk and Compliance Forum, October 8, 2020
- Co-moderator, “International Supply Chain and the U.S. Government Focus on China,” Winston & Strawn's Disruptive Technologies Legal Summit, September 30, 2020
- Co-presenter, “Third Party Management: Everyone Talks about Due Diligence, but how do we Operationalize it?” Consero, September 2020
- Co-panelists, “Russia Deep Dive: Staying Compliant with Primary and Secondary Sanctions Restrictions,” American Conference Institute, July 28, 2020
- Co-panelist, “Next Generation Screening: Pairing Artificial intelligence with Risk Intelligence,” Kharon & Accuity, August 20, 2020
- Co-panelist, “Implications for the Danish Maritime Community of Recent U.S. Government Sanctions Guidance,” Winston & Strawn, June 2, 2020
- Co-panelist, “Sanctions and the Shipping Sector," Center for a New American Security, May 27, 2020
- Co-panelist, “Recent Trends in Sanctions,” Winston & Strawn, April 29, 2020
- Co-presenter, “How to deter Russian aggression in an election year: Legislative options,” Atlantic Council, March 16, 2020
- Co-presenter, “Sanctions: What are they good for?” American Israeli Political Action Committee (AIPAC) March 1, 2020
- Moderator, “Gas Beyond an Energy Source – An Enabler of Trade and Industrialization in Latin America” Powering Africa Summit / Latin America Energy Forum, February 24, 2020
- Co-panelist, “Helms Burton Act Roundtable” American Society of International Law, Miami, Florida, February 14, 2020
- Co-presenter, “A 20/20 View on 2020’s Legislative and Regulatory Outlook” ACAMS Annual Anti-Financial Crime and Public Policy Conference, Washington, DC, February 6, 2020
- Airline Economics Growth Frontiers, “Economic Sanctions Developments and Disruptions for the Aviation Finance Sector”, Dublin, Ireland January 20, 2020
- Co-presenter, “Surviving the Tsunami of Global Regulations” Caribbean Regional Compliance Association Conference, St Lucia, November 8, 2019
- Speaker, “Disruptive Worldwide Landscape” Silicon Valley Disruptive Technologies Summit, Santa Clara, California, September 11, 2019
- Co-presenter, “U.S. Sanctions and Export Control – Are you up to speed and prepared?” Hong Kong General Chamber of Commerce, August 1, 2019
- Co-presenter, “U.S. Sanctions and Export Control – Are you up to speed and prepared?” American Chamber of Commerce in Shanghai, China, July 30, 2019
- Co-presenter, “U.S. Sanctions and Export Control – Are you up to speed and prepared?” Beijing, China, July 25, 2019
- Co-presenter, “International Update: Sanctions, Export Controls, and Immunity,” Legal Issues in Museum Administration, Washington, D.C., March 21, 2019
- Moderator, “Global standards, best practices and key challenges for international financial institutions in managing sanctions related risks,” Kharon Global Sanctions Summit, New York, New York, April 8, 2019
- Co-presenter, “International Sanctions: Status Quo?” 5th Meeting on Financial Services Compliance, EIZ, Europa Institute at University of Zurich, Zurich, Switzerland, November 13, 2018
- Co-presenter, “Bribery and corruption, money laundering, and sanctions: understanding financial crime risks and their impact on shipping,” 2018 MLA AGM, Franschhoek, South Africa, September 1, 2018
Webinar 05/10/22 - 05/12/22Winston & Strawn’s 2022 Health Care & Life Sciences Summit
Accolade 05/06/22Law360 Names Winston Attorneys to 2022 Editorial Advisory Boards
Pro Bono In Action 04/21/22Winston Aids Afghans Affected by the Taliban’s Takeover of Their Country
Article 03/16/22How Multinationals Can Withstand U.S.-China Trade Conflict
Media Mention 03/11/22Winston & Strawn Partner Cari Stinebower Provides Ongoing Analysis of Russian Sanctions
Media Mention 02/24/22Cari Stinebower Discusses How Russia’s War on Ukraine Will Affect the Global Economy
Media Mention 02/18/22Cari Stinebower Discusses Preparations for Possible Russia Sanctions on Bloomberg’s “Balance of Power”
Accolade 02/18/22Winston & Strawn Recognized in Chambers Global 2022
Media Mention 02/04/22Cari Stinebower Addresses Possible U.S. Sanctions Against Russia in Reuters Interview
Media Mention 01/31/22Cari Stinebower Discusses Russian Sanctions in The Wall Street Journal
Accolade 11/04/21Winston & Strawn Recognized in The Legal 500 Latin America 2022
Accolade 10/19/21Latinvex Recognizes Three Winston Attorneys on Latin America’s Top 100 Female Lawyers List
Webinar 10/19/21Environmental Enforcement Outlook in China for U.S. Companies
Media Mention 08/17/21Cari Stinebower Featured in The Wall Street Journal’s Risk & Compliance Journal
Accolade 07/14/21Winston & Strawn Recognized in Airfinance Journal’s Guide to Lawyers 2021
Accolade 06/10/21Winston & Strawn Recognized in The Legal 500 U.S. 2021
Accolade 05/19/21Winston & Strawn Recognized in Chambers USA 2021
Speaking Engagement 04/27/21China Landscape: Staying Compliant with Rapidly Changing Export Controls and Sanctions Regulations
Blogs & Podcasts
05/13/22OFAC Announces New Sanctions on Accounting, Trust/Corporate Formation, and Management Consulting Services to Russia
03/28/22Sanctions Summary – Russia Invasion of Ukraine
03/10/22White House Issues Executive Order on Crypto and Other Digital Assets
03/10/22Summary of EU Sanctions Targeting Russia
02/23/22Multinationals with Operations in China May Be Feeling Caught Between a Rock and a Hard Place
02/08/22China’s 2021 Negative List Increases Risks of VIE Investment
02/01/22Winston & Strawn’s International Trade Predictions for 2022
12/17/21Another Crack in the Protective Shell of Shell Companies
11/04/21OFAC’s Eye on Virtual Currencies – Cryptocurrency Regulation and Enforcement Updates
09/30/21Understanding China’s Variable-Interest Entities
09/03/21China Passed Personal Information Protection Law – How should we view this Chinese “GDPR”?
08/31/21OFAC Identifies SDNS Under PEESA Authorities and Clarifies Scope
08/16/21Takeaways from CFIUS’s Annual Report for 2020
08/13/21Cuba Fact Sheets Published by BIS and OFAC Encourage Exports to Support the Cuban People, but Challenges to Carrying Out Those Exports Remain
07/08/21President Biden’s Recent Statement Expressing Support for the United States’ Open Investment Policy and Its Potential Implications for CFIUS Reviews
06/23/21Nowhere to Hide: Treasury Builds Team Focused on Searching for Transactions Not Filed with CFIUS
06/04/21Biden Amends EO 13959, Removes Several Previously Designated Chinese Military Companies, and Designates 59 Chinese Companies as Chinese Military-Industrial Complex Companies
04/19/21Biden Administration Imposes Strict New Sanctions on Russia in Response to Cyber Attacks and Election Interference