Norman Law & Policy PLLC

Portrait of W. Caffey Norman

W. Caffey Norman, Owner

Independent counsel in Washington, D.C.

Practice

Two areas of concentration, each reflecting over four decades of experience at the federal and international level.

Banking/Foreign Sovereign Representation

Advises financial institutions and foreign governmental entities (including central banks) on regulatory, governance, and cross-border matters, with particular focus on the Middle East and North Africa.

Work spans bank regulation, correspondent relationships, and Washington representation. For UAE licensing/regulatory matters, Mr. Asrat Betru, formerly senior staff at the UAE Central Bank, is available for consultation.

Environmental/Chemical Regulation

Represents manufacturers and industry groups before EPA, OSHA, and state regulators on the control of hazardous chemicals, including toxic substances, stratospheric ozone depletion, and climate policy.

Has successfully challenged federal regulations in the U.S. Courts of Appeals, including the recent East Fork decision that changes how EPA regulates toxic chemicals.

About Us
Portrait of W. Caffey Norman

Mr. Norman practiced for decades in Washington, D.C. as a partner at a global law firm, before establishing an independent practice focused on banking and foreign sovereign representation alongside environmental regulatory work.

The focus of his international work has been advising financial institution/governmental clients on matters that may involve U.S. authorities and foreign central banks. His environmental practice has centered on the regulation of hazardous chemicals by federal and state agencies, and on the litigation that follows when a product or substance is targeted for phase-out.

Education
J.D., University of Virginia, 1977
A.B., University of Alabama, 1974
Clerkship
Hon. Walter P. Gewin, U.S. Court of Appeals for the Fifth Circuit, 1977–1978
Bar Admission
District of Columbia
Court Admissions
U.S. Supreme Court
U.S. Courts of Appeals for the Second, Third, Fifth, Eighth, Eleventh, and D.C. Circuits
U.S. District Court for the District of Columbia
Government Experience
U.S. Department of the Treasury, Senior Counsel for Banking, 1986

Representative Matters

Banking/Foreign Government

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, including sanctions and related U.S. policy initiatives. He represented Abu Dhabi in the BCCI scandal and the 20-year global liquidation that followed. 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.

Representative Experience

  • Representation of International Development Bank in connection with access to USD clearing following actions taken by Central Bank of Iraq.
  • Formation and representation of the U.S.-Ethiopia Business Council.
  • Removal of Bank of Khartoum from list of Specially Designated Nationals, and assistance in recovering frozen assets in the United States and Iraq.
  • Representation of Government of Sudan in connection with lifting of U.S. economic sanctions.
  • Washington representation of Government of Ethiopia.
  • Representation of Abu Dhabi Government and Ruling Family in BCCI scandal.
  • Representation of UAE Central Bank, UAE Insurance Authority, and UAE Securities & Commodities Authority on sanctions, FATF compliance, FATCA implementation, and other matters.
  • 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 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 U.S. presence.

Representative Matters

Environmental/Chemical Regulation

W. Caffey Norman’s environmental practice focuses on the regulation of hazardous chemicals by the Environmental Protection Agency, the Occupational Safety and Health Administration, the Consumer Product Safety Commission, and various state regulatory agencies. He has been particularly active in the subject areas of toxic substances, stratospheric ozone depletion, and climate change. For many years he has developed and implemented strategies to defend products targeted for phase-out or use reduction, including successful challenges to regulations in the U.S. Courts of Appeals. Most recently, his efforts led to a landmark decision fundamentally changing the way EPA regulates under the Toxic Substances Control Act (TSCA), East Fork Enterprises v. EPA, No. 24-60227.

Representative Experience

  • Represent challengers to 2024 TSCA rules on methylene chloride, perchloroethylene, trichloroethylene, and carbon tetrachloride in Third, Fifth, and Eighth Circuits.
  • Represented manufacturers of methylene chloride in Second Circuit litigation challenging first product ban after 2016 amendment of TSCA.
  • Advised major fluorochemicals manufacturer on regulatory and policy issues arising under Montreal Protocol on Substances That Deplete the Ozone Layer and U.N. Framework Convention on Climate Change, including successful representation in Mexichem Fluor Inc. v. EPA in D.C. Circuit (overturning SNAP delisting rules) and support for Congressional action to implement Kigali Amendment to Montreal Protocol.
  • Representation of Acrylonitrile Group in TSCA risk evaluation/rulemaking.
  • Formed/represented National Cannabis Roundtable.
  • Quarterbacked successful lobbying campaign on California AB 2998 regarding flame retardants and Proposition 65.
  • Negotiation of Premanufacture Notifications to settle enforcement actions against chlorinated paraffins importer 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.
  • Formed and represented several testing consortia.
  • Challenged OSHA methylene chloride standard in the U.S. Court of Appeals for the D.C. Circuit and negotiated satisfactory settlement with union support.
  • Organized coalition of formulators and users and initiated lobbying activities successfully challenging OSHA asbestos standard ban on aerosol brake cleaners.
  • Represented petitioner in successful litigation to overturn OSHA permissible exposure limit (PEL) update.

Publications

Press coverage and commentary on recent matters.

What the Fifth Circuit’s landmark ruling vacating the US EPA’s methylene chloride rule means for the TSCA programme

Legal and policy experts assess how the East Fork decision affects EPA’s risk evaluations and rules under TSCA, with comment from Caffey Norman on the court’s requirement that EPA weigh studies showing no effect.

5th Circ. Says EPA Went Too Far With Chemical Ban

Coverage of the Fifth Circuit's decision vacating the EPA's 2024 methylene chloride rule, in a case argued on behalf of East Fork Enterprises Inc. and Epic Paint Co.

Court Rejection of Methylene Chloride Rule to Shape Next Policy

Analysis of how the Fifth Circuit's ruling is likely to shape the EPA's future approach to chemical risk regulation under TSCA, with commentary on its implications for related cases.

Consultants

Specialists who work with Norman Law & Policy on matters requiring particular regional or regulatory expertise.