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), including the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR).
In particular, Cristina focuses on sanctions, including those maintained by the United States against Iran, Syria, Cuba, the Crimea, Donetsk and Luhansk regions of Ukraine, North Korea, Russia, Venezuela and Belarus. 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, as well as matters involving other restricted parties, including parties on OFAC's Sectoral Sanctions Identifications List (SSI List) and the BIS Entity List.
Cristina's practice includes compliance advice, including on classification and licensing requirements, internal investigations, and corporate due diligence and transactional matters.
In addition, Cristina 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.
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.
"The Expected (and Unexpected) Lessons from Recent Enforcement Actions: Key Takeaways on the Agencies' Areas of Focus and the Impact on Your Compliance Strategy," ACI's Forum on Digital Assets Compliance: AML, Sanctions & Fraud, October 13, 2022, New York, NY (Speaker)
"An international perspective on the Ukraine-/Russia-related sanctions," International Chamber of Commerce, July 15, 2022 (Speaker)
"Fireside Chat with BIS, DDTC and DTSA – Exploring the Latest in Export Controls and Enforcement," Momentum Events 15th National Anti-Corruption, Export Controls, and Sanctions (A.C.E.S) Compliance Summit, May 17, 2022 (Moderator)
"Trade Implications of the Crisis in Ukraine," CITBA Annual Meeting, May 3, 2022 (Speaker)
"Responding to Russia: Sanctions, Prohibitions and The Law," TechGC Webinar, March 10, 2022 (Speaker)
"Life After an Enforcement Action: Lessons Learned and How to Strengthen Compliance Going Forward," American Conference Institute's 15th Flagship Conference on US Economic Sanctions Enforcement and Compliance, December 7, 2021, Washington, DC (Speaker)
"The Sanctions Intensive: Hindsight 20/20 - Enforcement Breakout Session," Momentum Events 14th National Anti-Corruption, Export Controls, and Sanctions (A.C.E.S) Compliance Summit, June 29, 2021 (Moderator)
"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, May 12, 2020 and June 25, 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)
Export Compliance Manager, "Internal compliance and external optics," April 2022 (co-author with Jessica Lynd)
Wolters Kluwer Banking & Financial Services Report, "Review of Anti-Money Laundering and Sanctions Policy and Enforcement," January 2019 (co-author with Nicole Erb)
WorldECR, "Venezuela sanctions target gold and corruption," November 2018 (co-author with Richard Burke and Nicole Erb)
Expert Analysis: Election Interference Sanctions Expand Compliance Risks, Law360, September 24, 2018, (co-author with Nicole Erb, Richard Burke and Claire DeLelle)
World Export Controls Review, "US Issues Further Syria Sanctions" (co-author with Richard Burke)
Virginia Review of Asian Studies, "Japan's Deployment of Self-Defense Forces to Iraq, 2004" (author)
Ranked lawyer, Chambers USA 2021-2022: International Trade: Export Controls & Economic Sanctions
Next Generation Partner, The Legal 500 2020-2022: 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