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Guillermo Christensen is a partner in Ice Miller’s Data Security and Privacy and White Collar Defense Groups. Guillermo combines his experience as an attorney, a former CIA intelligence officer and a diplomat with the U.S. Department of State to shape and inform the advice he provides to clients on various enterprise risks involving cybersecurity and national security law. His cybersecurity experience ranges from conducting information security risk assessments that take a “whole of company” approach to managing responses to security incidents and breaches, including those where a nation-state or insider threat may be involved. Guillermo also counsels clients in managing national security reviews through the Committee on Foreign Investment in the United States (CFIUS), particularly those involving high-technology and critical infrastructure sectors.
 
In the international trade area, Guillermo regularly represents clients in complying with anti-corruption laws such as the Foreign Corrupt Practices Act (FCPA) and economic sanctions and embargoes administered by the Office of Foreign Assets Controls (OFAC). His work includes handling cross-border investigations, compliance reviews and pre-acquisition diligence. 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.
 
Guillermo previously worked in the Washington, D.C. offices of two international law firms.
 
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 experiences 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 US intelligence community.
 
Guillermo subsequently returned to public service in 2010-2011 as the Science and Technology Advisor to the U.S. Mission to the Organization for Economic Cooperation and Development (OECD) in Paris.  There, Guillermo was responsible for managing and conceptualizing U.S. policy in the areas of technology, telecommunications, privacy and science at the OECD. He advocated for U.S. interests across a range of technology issues, such as cybersecurity, data privacy, cloud computing, cross-border data flows and intellectual property.  
 
Guillermo earned his juris doctor in 2005 from the Georgetown University Law Center while working at the CIA. His law school education included participation in a joint GULC-University College of London program on EU and European Law Program. He was also a senior member of the Georgetown Journal of International Law. Guillermo received his Bachelor of Arts in International Relations in 1988 from American University and earned his master’s degree in Foreign Service from Georgetown University’s School of Foreign Service.
 
Guillermo remains active in a number of national security related areas, including as a life member of the Council on Foreign Relations and as a participant in the U.S. Department of State’s Speaker’s Bureau.  He is a member of the Sedona Conference and has contributed to WG6 and WG11 projects on data security and ephemeral messaging and law enforcement. He is a frequent speaker and moderator on national security and cybersecurity topics in the U.S. and internationally and is a current member of the Law360 Editorial Board on Cybersecurity.
 
Guillermo is licensed to practice law in the District of Columbia, New York and Virginia.
 
Reported and Representative Cases
Cybersecurity and Data Privacy
  • Assisted client with ransomware attacks on "family jewel" type assets
  • Negotiated with the U.S. Government following a breach in a sensitive defense related contract
  • Counseled client in managing ransomware incident and insurance claims
  • Counseled a client after key systems were hijacked by hackers and posed a mission critical threat to their systems. Assisted the client in securing and recovering their assets
  • Trained energy clients at the staff and management level on assessing and scoping cybersecurity threats
  • Advised clients on intellectual property-related matters involving information security and associated systems
  • Counseled on cybersecurity dimensions of M&A transactions
Corporate Investigations and FCPA Compliance
  • Designed and implemented a multi-year global risk assessment for an international oil services company to mitigate FCPA, OFAC and data privacy risks
  • Conducted a rapid turnaround internal investigation for an energy company involving allegations around fraud and corruption in India and the Middle East
  • Conducted a year-long internal investigation for a Fortune 100 high technology company in South America and Europe
  • Conducted an internal investigation in Colombia for a Fortune 100 company involving hiring practices and government officials
  • Conducted internal investigations and performed risk assessments relating to FCPA compliance, among the locations involved are Myanmar/Burma, Brunei, Chad, Saudi Arabia, Equatorial Guinea, Angola, Singapore, China, Russia, the UAE, Thailand, Malaysia, Mexico, Iraq, Egypt, Colombia and the UK
  • Fortune 500 oil services company – conducted acquisition due diligence on corporate target and post-closing diligence
  • Fortune 1000 company – consulted on enhancements to global anticorruption policies  and procedures and training program
  • Russian telecommunications company – due diligence review in connection with planned acquisition of telecommunications company
  • Oil services company – drafted anticorruption policies and associated procedures and provided training to board, senior management and sales teams
Regulatory and National Security Law
  • Secured regulatory approvals including CFIUS for transaction involving weapons manufacturer
  • Led team counseling a global information and communications technology (ICT) solutions provider in representation before CFIUS in connection with proposed U.S. investment activities
  • U.S. aviation maintenance and repair company – representation before CFIUS, State Department and Defense Security Service in connection with acquisition by AsiaPac purchaser
  • Secured CFIUS clearance by European aerospace company in a $1 billion acquisition of commercial and military aircraft business
  • International oilfield services company – comprehensive audit of export controls and sanctions compliance programs in connection with U.S. government investigation
  • Various multinational companies – regularly developed and oversaw implementation of global export control and sanctions compliance programs
  • Large U.S. chemicals company – conducted comprehensive review of technology at all U.S. facilities to assess compliance with U.S. technology “deemed export” controls
  • International energy companies – advised on compliance with Crimea and Ukraine sanctions
  • Middle Eastern companies – counseled on compliance with U.S. Iran and Syria sanctions
International  Arbitration and Complex Business Litigation
  • Sovereign state – arbitration of initial claims under a joint dispute board arising from a hydropower project
  • Represented the deposed head of a democratically elected government on a range of international legal matters
  • Represented petitioner before U.S. Supreme Court on statute of limitations appeal (BP Am. Prod. Co. v. Burton, 549 U.S. 84 (2006))
Firm Publications
News
Blog Posts
Published In
  • "Does Your Cyber Policy Cover Funds 'Stolen' During Email Spoofing?" Inside Indiana Business, November 6, 2019
  • "UK Litigation and Guidance Highlight Cybersecurity Risk," Law360, January 10, 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
Speaking Engagements
  • Keynote – “Cybersecurity Threats to Utility Infrastructure,” Indiana State Bar Energy Section Annual Conference, Bloomington, IN, September 11, 2019
  • Speaker – “GDPR, CCPA and More:  A Connected World Accelerates the Privacy Discussion,” RealComm Annual Conference, Nashville, TN, June 13, 2019
  • Speaker – “Gone with the Wind: Your Security Walls are Down,” Government Finance Officers Association, Los Angeles, May 22, 2019
  • Moderator – Panel on Developing an Effective Cyberpolicy for the United States, Council on Foreign Relations International Fellowship Conference, New York, May 3, 2019
  • ABA GPSolo Annual Conference, Cybersecurity and Law Firms, New York City, May 2, 2019
  • Panelist –Ephemeral Messaging and E-Discovery Challenges Panel, ABA 13th Annual National Institute on E-Discovery, Chicago, April 26, 2019
  • Panelist – “5G Technology and Security Challenges,” Conecta Mexico 2019,  Mexico City, April 4, 2019
  • Keynote – Cybersecurity and FinTech, eShow Mexico 2019, Mexico City, April 3, 2019
  • “The Current Challenges Facing Mexico in Cybersecurity,” Interview with Ana Maria Salazar, El Financiero Television Show, April 2, 2019
  • “Cybersecurity Challenges to Critical Infrastructure,” Houston Compliance Exchange, March 7, 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, 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 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
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