W. Caffey Norman represents a number of foreign governments and financial institutions in connection with legal problems and policy issues arising out of their investments and activities. He has advised several banks in connection with US regulatory matters and asset freeze litigation. More generally, Caffey is active in assisting foreign governments and central banks develop regulatory frameworks and in representation before US policymakers in Washington DC.

    Caffey also represents chemical companies and associations in connection with the regulation of toxic chemicals and the development of mechanisms to address climate change and stratospheric ozone depletion. If there is a single theme in his practice, it is helping clients evaluate and address risk where governmental action is involved, particularly in crisis situations.

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    Government/Financial Services

    • Representation of investor group in successful recovery of $500 million wire transfer frozen for over a year by Noor Bank in Dubai.
    • Advice to GCC “satellite banks” in investigations of possible sanctions violations arising out of their UAE operations, and in developing best practices for sanctions/AML compliance.
    • Representation of Government of Sudan in connection with lifting of US economic sanctions.
    • Removal of Bank of Khartoum from list of Specially Designated Nationals, and assistance in recovering frozen assets in the US and Iraq.
    • Representation of Abu Dhabi Ruling Family in BCCI scandal.
    • Representation of UAE Central Bank, UAE Insurance Authority and UAE Securities & Commodities Authority on FATCA implementation, sanctions, FATF compliance and other matters.
    • Advice to foreign banks regarding establishing a US presence.

    Environmental

    • Represent manufacturers of methylene chloride in litigation in Second and Ninth Circuits challenging first product ban and first risk evaluation following 2016 amendment of Toxic Substances Control Act (TSCA). 
    • Represent four of first ten substances subject to risk evaluations under amended TSCA.
    • Counsel to National Cannabis Roundtable.
    • Advise major fluorochemicals manufacturer in regulatory and policy issues arising under Montreal Protocol on Substances That Deplete the Ozone Layer and UN Framework Convention on Climate Change, including successful representation in Mexichem Fluor Inc. v. EPA in DC Circuit (overturning SNAP delisting rule), and support for EPA action to implement Kigali Amendment to Montreal Protocol.
    • Representation of chlorinated paraffins manufacturer in EPA enforcement action and successful defense of threatened product ban.
    • Participated in rulemakings and litigation challenging NESHAPs for dry cleaning, vapor degreasing, wood furniture manufacturing and other sources.
    • Challenged OSHA methylene chloride standard in DC Circuit and negotiated satisfactory settlement with union support.
    • Organized coalition of formulators and users and initiated lobbying activities successfully challenging OSHA asbestos standard to remove ban on aerosol brake cleaners.

    Education

    • University of Virginia, J.D., 1977
    • University of Alabama, A.B., 1974

    Admissions

    • District of Columbia, 1979

    Courts

    • U.S. Court of Appeals for the 11th Circuit
    • U.S. Court of Appeals for the 5th Circuit
    • U.S. Court of Appeals for the District of Columbia Circuit
    • U.S. District Court for the District of Columbia

    Clerk Experience

    • U.S. Court of Appeals for the 5th Circuit
      Hon. Walter P. Gewin
      August 1977 - August 1978

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    • FATCA Overview, Thomson Reuters GCC 5th Annual Compliance and AML Seminar, Riyadh (March 27, 2013).
    • FATCA Compliance, U.A.E. Central Bank Conference (March 21, 2013).
    • FATCA Intergovernmental Agreements, Thomson Reuters GCC FATCA Seminar, Dubai (June 11, 2012).
    • Banking and Financial Institutions Law Alert: “U.S. Sanctions Targeting Iran and Their Possible Impact on Non-U.S. Financial Institutions,” Patton Boggs Publication, (July 6, 2010).
    • Impact of U.S.A. PATRIOT Act on Banking and Remittance Business, U.A.E. Central Bank Conference (May 10, 2006).
    • Author, “Principles of Shari’a in Islamic Finance and Their Application for Western Investors,” Middle East & North Africa Business Guide 2004/2005, 86-90.
    • Author, Letters, Toxicology 208: 171-172 (2005), Environmental Forum (May/June 2002), Science (October 18, 1996), Am. J. Ind. Med. 30:508-509 (1996).
    • Author, “Risk Assessment,” The Environmental Law Handbook (BNA, 1995).

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