Cristina Brayton-Lewis

Partner, Washington, DC

Biography

Overview

Cristina Brayton-Lewis advises clients on a variety of regulatory matters, including compliance with export controls and economic sanctions laws and regulations administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC); the US Department of Commerce's Bureau of Industry and Security (BIS) and the US State Department's Directorate of Defense Trade Controls (DDTC).

In particular, Cristina focuses on comprehensive primary and secondary sanctions, including those maintained by the United States against Iran, Syria, Sudan, Cuba, the Crimea region of Ukraine and North Korea. She also advises with respect to the sectoral sanctions maintained by the United States against Russia and Venezuela. Cristina's sanctions expertise includes matters involving designated parties on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List), including applications to unblock assets.

Cristina also provides compliance advice, such as classification and licensing requirements, under the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR). In addition, she advises clients regarding antiboycott requirements maintained by the Department of Commerce and the Department of the Treasury.

Beyond compliance advice, Cristina also assists with internal investigations of possible sanctions and export control violations, as well as assisting companies with any Voluntary Self-Disclosures (VSD) to the relevant government agencies.

Prior to joining White & Case, Cristina was a Special Assistant Attorney General for the District of Columbia, where she prosecuted criminal matters in Superior Court of DC. She also interned at a leading law firm in Spain.

During law school, Cristina was an Administrative Articles Editor for the Georgetown Journal of Legal Ethics and a member of the Barrister's Council Arbitration Team.

Bars and Courts
Virginia State Bar
District of Columbia Bar
Education
JD
Georgetown University Law Center
BA
University of Virginia
Languages
English
Spanish

Experience

Representative Economic Sanctions Matters

Provision of US economic sanctions compliance advice to a number of European, Middle Eastern and Asian financial institutions.

Obtained authorization for the unblocking of over US$30 million in erroneously blocked assets of a Belarusian state-owned commodities producer.

Successfully obtained Trade Sanctions Reform and Export Enhancement Act (TSRA) licenses for numerous pharmaceutical corporations for exports of medicine and medical devices to Iran and Sudan, as well as transactional licenses for activities involving Syria, the Crimea region of Ukraine and designated parties.

Assisted in the preparation of Economic Sanctions Compliance Programs for the technology industry and oil & gas industry.

Representative Export Control Matters

Conducted internal investigations in support of Voluntary Self- Disclosures to BIS of potential export control violations for companies in the technology and internet-based services sector.

Represented defense service providers and brokers in the registration and licensing process before DDTC, including assistance preparing Technical Assistance Agreements (TAA) and submission of VSDs.

Assisted in the preparation of Export Control Compliance Programs for the defense industry, tech industry, semiconductor industry and oil & gas industry.

Advised clients in the aviation, manufacturing, semiconductor, software, technology, oil & gas, and defense industries on appropriate export control classification numbers (ECCN) of goods and services, applied for commodity classifications requests (CCATS), as well as applicable restrictions on exports.

Speaking Engagements

"Anti-Money Laundering and Sanctions Compliance for Corporates," American Bar Association Business Law Bonus CLE Program, August 6, 2020 (Speaker)

"The Road to 'Business As Usual' for America's Pharma Industry," White & Case Client Webinar, June 25, 2020 and May 12, 2020 (Speaker) 

"Trade Talk: Legislative Initiatives to Strengthen US Sanctions," Association of Women in International Trade (WIIT), April 29, 2019, Washington, DC (Moderator)

"Voluntary Self-Disclosures to OFAC: Best Practices and What Can Possibly Go Wrong," Association of Certified Sanctions Specialists and sanctionsalert.com, February 28, 2018, Webinar (co-Speaker with Jason Rhoades)

"Sanctions and Export Control Considerations for your Investment Strategy – A closer look at ZTE, Iran, Russia and North Korea," White & Case Taiwan Seminar: Cross-border Trends Relevant to Taiwanese Investors and Companies, July 19, 2018, Taipei, Taiwan (Co-speaker with Nicole Erb)

"Sanctions: What Happens There Can Impact You Here," ACAMS Connecticut Chapter, May 19, 2017 (Speaker)

"U.S. Implementation of the Iran Sanctions Relief in the Joint Comprehensive Plan of Action," Co-Sponsored by the American Bar Association (ABA) and WIIT, February 23, 2016 (Moderator)

"Trade Talk on New Cuba Sanctions and Export Control Regulations," WIIT, February 5, 2015 (Moderator)

"Export Controls and Economic Sanctions: Compliance Considerations for the Tech Industry," Journey 2014, October 30, 2014 Tel Aviv, Israel,  (Speaker)

Publications

“Anti-Money Laundering and Sanctions Compliance for Corporates,” American Bar Association Business Law Bonus CLE Program, August 6, 2020, (Speaker)

"The Road to 'Business As Usual' for America's Pharma Industry," White & Case Client Webinar, June 25, 2020 and May 12, 2020, (Speaker) 

"Trade Talk: Legislative Initiatives to Strengthen US Sanctions," The Association of Women in International Trade (WIIT), April 29, 2019, Washington, DC, (Moderator)

"Voluntary Self-Disclosures to OFAC: Best Practices and What Can Possibly Go Wrong," Association of Certified Sanctions Specialists and sanctionsalert.com, February 28, 2018, Webinar, (co-Speaker with Jason Rhoades)

"Sanctions and Export Control Considerations for your Investment Strategy – A closer look at ZTE, Iran, Russia and North Korea," White & Case Taiwan Seminar: Cross-border Trends Relevant to Taiwanese Investors and Companies, July 19, 2018, (Co-speaker with Nicole Erb)

"Sanctions: What Happens There Can Impact You Here," ACAMS Connecticut Chapter, May 19, 2017, (Speaker)

"U.S. Implementation of the Iran Sanctions Relief in the Joint Comprehensive Plan of Action," Co-Sponsored by the American Bar Association (ABA) and The Association for Women in International Trade (WIIT), February 23, 2016, (Moderator)

"Trade Talk on New Cuba Sanctions and Export Control Regulations," The Association for Women in International Trade (WIIT), February 5, 2015, (Moderator)

"Export Controls and Economic Sanctions: Compliance Considerations for the Tech Industry," Journey 2014, October 30, 2014, Tel Aviv, Israel,  (Speaker)

Awards and Recognition

Next Generation Partner, The Legal 500 2020: International Trade

Rising Star, The Legal 500 2019: International Trade

Selected to the Washington DC Super Lawyers Rising Stars list (2016-Present)

ABA Export Controls and Economic Sanctions Steering Committee Member

Co-Chair, Export Control and Sanctions Section of the Association of Women in International Trade