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.
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.
"Trade Talk: Legislative Initiatives to Strengthen US Sanctions," hosted 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," February 28, 2018: Association of Certified Sanctions Specialists and sanctionsalert.com, 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", July 19, 2018: White & Case Taiwan Seminar: Cross-border Trends Relevant to Taiwanese Investors and Companies, (Co-speaker with Nicole Erb)
"Sanctions: What Happens There Can Impact You Here", May 19, 2017: ACAMS Connecticut Chapter, (Speaker)
"U.S. Implementation of the Iran Sanctions Relief in the Joint Comprehensive Plan of Action", February 23, 2016: Co-Sponsored by the American Bar Association (ABA) and The Association for Women in International Trade (WIIT), (Moderator)
"Trade Talk on New Cuba Sanctions and Export Control Regulations", February 5, 2015: The Association for Women in International Trade (WIIT), (Moderator)
"Export Controls and Economic Sanctions: Compliance Considerations for the Tech Industry", October 30, 2014: Journey 2014, Tel Aviv, Israel, (Speaker)
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)
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