Kimberly Brown works with clients on a variety compliance and enforcement related matters involving economic sanctions and export controls. This work includes drafting advisory opinions, requests for interpretive guidance, requests for specific licenses and responses to administrative subpoenas. In addition, she conducts sanctions risk assessments and review sanctions policies and procedures for technology companies.
Ms. Brown has nearly 15 years of experience as a lawyer working in U.S. sanctions, with six years of that experience coming from the time she spent at the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) as a Policy Analyst and Senior Enforcement Officer. During her tenure at OFAC, Ms. Brown worked extensively on the Iran sanctions program, including drafting interpretative guidance and the Statement of Licensing Policy on Internet Freedom in Iran, and investigating violations of the Iranian Transactions and Sanctions Regulations (“ITSR”) and other sanctions programs. Additionally, she served as the government’s expert witness on sanctions in a criminal prosecution related to the illegal export of telecommunications services to Iran. Prior to her time at OFAC, Ms. Brown spent several years at the Department of Homeland Security (“DHS”), where she served as an Attorney-Advisor. Since leaving the government, Ms. Brown has remained in the sanctions and international trade compliance space working on the sanctions compliance teams for both IBM, and Payward (aka “Kraken”).