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 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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    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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    • Represent manufacturers of substances subject to first rules proposed following 2016 passage of the Lautenberg Act amending the Toxic Substances Control Act (TSCA), resulting in abandonment of those proposals. Represent four of first 10 substances subject to risk evaluations under amended TSCA.
    • Represent 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.
    • Negotiation of Premanufacture Notifications to settle enforcement actions against chlorinated paraffins importer and successful defense of threatened product ban.
    • Participate in rulemakings and litigation challenging NESHAPs for dry cleaning, vapor degreasing, wood furniture manufacturing and other sources.
    • Formed and represented several testing consortia.
    • Challenged OSHA methylene chloride standard in the US Court of Appeals for the DC Circuit and negotiated satisfactory settlement with union support.
    • Organized coalition of formulators and users and initiated lobbying activities successfully challenging OSHA asbestos standard for removal of ban on aerosol brake cleaners. 
    • Represented petitioner in successful litigation to overturn OSHA permissible exposure limit (PEL) update.

    • Representation of Abu Dhabi Ruling Family in BCCI scandal. 
    • Removal of Bank of Khartoum from list of Specially Designated Nationals, and assistance in recovering frozen assets in the US and Iraq.
    • Representation of Government of Sudan in connection with lifting of US economic sanctions. 
    • Representation of UAE Central Bank, UAE Insurance Authority and UAE Securities & Commodities Authority on FATCA implementation, sanctions, FATF compliance and other matters.
    • Representation of major GCC financial institutions in investigations of possible sanctions violations and in developing best practices for sanctions/AML compliance.
    • Advice to foreign banks regarding establishing a US presence.

    • 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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