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Guillermo S. Christensen

Guillermo Christensen is a partner in the firm’s Washington, D.C. office. He is a member of the Antitrust, Competition, and Trade Regulation practice group.

Guillermo combines his experience as a former CIA intelligence officer, a diplomat with the U.S. Department of State, and an attorney to shape and inform the advice he provides to clients on enterprise risks involving cybersecurity, national security, and complex international business matters. Drawing on his national security background, Guillermo counsels clients in dealing with economic sanctions and embargoes administered by the Office of Foreign Assets Control (OFAC), including complex technology matters involving China, or fast moving compliance questions around ransomware payments. His work in national security-related mergers, acquisitions, and investments includes those requiring review by the Committee on Foreign Investment in the United States (CFIUS) or those involving export controls or the National Industrial Security Program (NISPOM). In the CFIUS context, Guillermo has worked in particular on high-technology, defense sector and critical infrastructure deals involving China, Russia, the Middle East, and Europe.

Guillermo represents clients in complying with anti-corruption laws such as the Foreign Corrupt Practices Act (FCPA) and OFAC investigations and voluntary disclosures. His work includes handling cross-border investigations, compliance reviews, and pre-acquisition diligence, and post-acquisition integration. He has investigated matters in South America, Africa, Asia, and the Middle East involving companies operating in the energy, high-technology, defense, and transportation sectors. He also advises companies on the adequacy of internal controls and compliance policies, and has set up compliance programs from the ground up for companies expanding into international markets, including training programs and board-level market entry advice.

Prior to becoming a lawyer, Guillermo served as an intelligence officer with the CIA for 15 years in a variety of domestic and international assignments. His experience included inter-agency roles with the Departments of Defense and State, the FBI and several national intelligence fusion centers. In 2001, Guillermo was selected by the CIA Director to serve as the National Intelligence Fellow to the Council on Foreign Relations in New York, a position designated for an officer on the cusp of senior leadership within the U.S. intelligence community.

  • Life Member, Council on Foreign Relations
  • Risk Advisor with the Risk Assistance Network Exchange (RANE)
  • Co-President, DC Metro Chapter, Private Directors Association
  • Co-Chair, National Security Subcommittee, DC Bar Criminal Law Committee
  • Board Member, International Advisory Board, Reves Center for International Studies, College of William & Mary
  • Hispanic National Bar Association
  • Leadership Council on Legal Diversity, 2016 Baker Botts Fellow
  • International Association of Privacy Professionals
  • Association of Former Intelligence Officers
  • The OSS Society
  • Central Intelligence Retirees Association
  • Private Sector Member, Department of Homeland Security and Director of National Intelligence Analytic Exchange Program 2019-2020 (Geopolitical Cyber Threats) and 2020-2021 (Cyberlaw)
  • Father’s Club, Gonzaga College High School
  • Treasurer Highview HOA
  • Speaker - "Cryptocurrencies and Ransomware; DEFCON29 Cryptovillage," August 2021Speaker - "Ransomware con Guillermo Christensen (Spanish Podcast), El Monero Podcast," August 2021
  • Panel Moderator – "Liability for Companies in Cyberbreaches," Tortora Brayda Institute, June 23, 2021
  • Panelist – "Cybersecurity & Law: Emerging Legal Precedents that Directors Need to Know," Private Directors Association Webinar, 10 June and 22 June 2021
  • Panelist – "Hot Topics," Tortora Brayda Institute, 26 May 2021
  • Speaker – "OFAC Ransomware Advisory," ABA Export Controls Committee Webinar, 16 March 2021
  • Speaker – "Cybersecurity Risk for Boards," RANE and NASDAQ Virtual Conference, 3 December 2020
  • Panelist – "Ephemeral Messaging: Balancing the Benefits and Risks," Wickr and Driven Webinar, 8 June 2020
  • Panelist – Congressional Roundtable, “Understanding the Cyber Threats and Actors Exploiting the COVID-19 Crisis,” U.S. House of Representatives Committee on Financial Services, 28 May 2020
  • Speaker – “Inside the Firm: COVID-19 and the National Security Implications,” Litera TV, 22 May 2020
  • Keynote – “Cybersecurity Threats to Utility Infrastructure,” Indiana State Bar Energy Section Annual Conference, Bloomington, IN, 11 September 2019
  • Speaker – “GDPR, CCPA and More: A Connected World Accelerates the Privacy Discussion,” RealComm Annual Conference, Nashville, TN, 13 June 2019
  • Speaker – “Gone with the Wind: Your Security Walls are Down,” Government Finance Officers Association, Los Angeles, CA, 22 May 2019
  • Moderator – Panel on Developing an Effective Cyberpolicy for the United States, Council on Foreign Relations International Fellowship Conference, New York, NY, 3 May 2019
  • ABA GPSolo Annual Conference, Cybersecurity and Law Firms, New York, NY, 2 May 2019
  • Panelist –Ephemeral Messaging and E-Discovery Challenges Panel, ABA 13th Annual National Institute on E-Discovery, Chicago, IL, 26 April 2019
  • Panelist – “5G Technology and Security Challenges,” Conecta Mexico 2019, Mexico City, Mexico, 4 April 2019
  • Keynote – Cybersecurity and FinTech, eShow Mexico 2019, Mexico City, Mexico, 3 April 2019
  • “The Current Challenges Facing Mexico in Cybersecurity,” Interview with Ana Maria Salazar, El Financiero Television Show, 2 April 2019
  • “Cybersecurity Challenges to Critical Infrastructure,” Houston Compliance Exchange, 7 March 2019
  • Keynote – “Private-Public Sector Cybersecurity Cooperation” – Qatar National Bank 5th Annual Cybersecurity Forum, Doha, November 2018
  • Speaker – “Cybersecurity Fundamentals for Companies” – Overseas Security Advisory Committee, Doha, November 2018
  • Speaker – “Spycraft and the Hacker Mindset” – DRI Cybersecurity Conference, Chicago, IL, September 2018
  • Speaker – “International Cooperation in Corruption Investigations, Buenos Aires, Argentina
  • Speaker – “Legal Privilege in Cross-Border Investigations,” Corporate Parity 3rd Annual Anti-Corruption Conference, Amsterdam, The Netherlands, May 2018
  • Speaker – “Spy Craft: Nation-state Cyber Threats and Managing Enterprise Risks,” Hispanic National Bar Association Corporate Counsel Conference, March 2018
  • Speaker – “Fireside Chat on Cybersecurity and Global Risks,” Control Risks RiskMap 2018 Conference, January 2018
  • Moderator – “Protecting Attorney Client Privilege During a Data Breach Investigation,” Insecurity 2017 Conference, November 2017
  • Moderator and Speaker – “Cyber Breaches: What General Counsels Need to Know About Detection and Response,” Brown Rudnick Cyber Conference, November 2017
  • Speaker – “Cybersecurity: What Compliance Officers Need to Know,” Houston Compliance Counsel Exchange, October 2017
  • Panelist – “Cybersecurity Risk and Insurance,” Hispanic National Bar Association Annual Convention, September 2017
  • “Law Firms and Data Security,” Sedona Conference Working Group 11, September 2017
  • Panelist – ABA Section of International Law, Data Security in the Panama Paper Context, April 2017
  • Speaker – “China’s New Cybersecurity Law,” SINET ITSEF Palo Alto Conference, March 2017
  • Panelist – “Law Firm Data Security,” Sedona Conference Working Group 11, January 2017
  • Speaker – “Cybersecurity Threats to Critical Infrastructure,” St. John’s University School of Risk Management, November 2016
  • Speaker – “Cybersecurity Challenges to Public Utilities,” Conference for the American Public Power Association, October 2016
  • Speaker – St. John’s University Conference on Geopolitical Risk and Cybersecurity, October 2015
  • Moderator – Closing Plenary Panel on Technology, Council on Foreign Relations Conference on Diversity in International Relations, 2014
  • Presenter – “Cyber Crimes, Ethics & Social Media,” Hispanic National Bar Annual Conference, September 2013
  • Moderator – “Forecasting the Future: Social Media as an Intelligence Tool,” Council on Foreign Relations, February 2012
  • Speaker – “Data Governance and US Policy,” IBM Data Governance Conference, Talleyrand Center, 2011
  • Speaker - "Cryptocurrencies and Ransomware; DEFCON29 Cryptovillage," August 2021
  • Speaker - "Ransomware con Guillermo Christensen (Spanish Podcast), El Monero Podcast," August 2021
Additional Thought Leadership Pages
Additional News & Event Pages
  • "Commentary on Ephemeral Messaging," The Sedona Conference Working Group 6 on International Electronic Information Management, Discovery and Disclosure (WG6), July 2021
  • "Courts Should Use Encryption Technology to Stay Safe," Bloomberg Law, 26 April 2021
  • "Self-Hosted Cryptocurrency Wallets Face New Privacy Hurdles," Law360, 5 January 2021
  • "Indiana High Court Says Government Can't Unlock Your Phone," Bloomberg Law, 20 July 2020
  • "Cyber-Criminals Revive W-2 Scams Ahead of Extended Tax Deadline," Inside Indiana Business, 22 June 2020
  • "Does Your Cyber Policy Cover Funds 'Stolen' During Email Spoofing?" Inside Indiana Business, November 6, 2019
  • "UK Litigation and Guidance Highlight Cybersecurity Risk," Law360, 10 January 2019
  • “How Cellphone Chips Became a National-Security Concern,” WJS, March 2018
  • “Broadcom’s Deal for Qualcomm is in Serious Jeopardy, and It Might Have to Abandon Its Bid and Come Back Later," CNBC, March 2018
  • “For Equifax’s Legal Team, Breach Likely to Bring Litigation Challenges, High Price Tag,” Law.com, September 2017
  • “Law360 Privacy/Consumer Protection Editorial Advisory Board,” Law360, March 2017
  • “As Hacking Incidents Rise, Cybersecurity to Remain a Priority under Trump,” The Street, November 2016
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