The Downton Abbey actress is rumoured to be the frontrunner for Marvel Studios' sequel, according to the Daily Express.
She will be available for shooting in 2013 following the conclusion of the third season of ITV's period drama.
Findlay is competing against four other actresses: Game of Thrones' Emilia Clarke, Teresa Palmer (I Am Number Four), Imogen Poots (28 Weeks Later) and Alison Brie (Mad Men).
Downton's popularity in the US is thought to give Findlay a good chance of winning out against the opposition.
Frank Grillo was most recently reported to be closing a deal to appear as Crossbones in the film.
Captain America: The Winter Soldier will be released on April 4, 2014.