Christopher T. Timura is Of Counsel in the Washington D.C. office of Gibson, Dunn & Crutcher LLP and a member of the firm's International Trade Practice Group.
Mr. Timura helps clients solve regulatory, legal and political problems that arise at the intersection of national security, trade, and foreign policy, and to develop corporate social responsibility (CSR) and environmental, social, and governance (ESG) strategies, policies, and procedures. His clients range from start-ups to Fortune 50 companies, and span industries including aerospace, auto, energy (conventional and renewable; production, storage and transmission), chemicals, finance, infrastructure and development, information security, insurance, investment management and advising, medical device, pharmaceuticals, private equity, semiconductors, telecommunications and travel.
Mr. Timura counsels clients on export controls (ITAR and EAR), economic sanctions, and anticorruption, and represents them before the departments of State (DDTC), Treasury (OFAC and CFIUS), Commerce (BIS), Homeland Security (CBP), and Justice in investment reviews and in voluntary and directed disclosures involving both civil and criminal enforcement actions.
Mr. Timura also assists clients working with emerging and controlled technologies in developing effective international trade licensing and CSR strategies to support global supply chains and customer bases. With in-house counsel, boards, and other business personnel, he helps to identify and leverage existing business processes to build integrated international trade, anticorruption and CSR-related data gathering, analysis, investigation, and reporting programs. In M&A and other transactions, he conducts expedited diligence on national security, international trade compliance, and ESG issues.
On a pro bono basis, Mr. Timura assists clients with immigration issues and works with several international rule of law training NGOs on the investigation and enforcement of anti-human trafficking and forced labor laws, wildlife trafficking laws, and on related legislative reform.
Mr. Timura received his J.D. from the University of Michigan Law School, where he served as an articles editor of the Michigan Journal of International Law and received the William W. Bishop Jr. Award for his performance in the international law curriculum. In 2001, he served as a law clerk to a member of the United Nations International Law Commission. Mr. Timura also earned a Ph.D. in cultural anthropology at the University of Michigan. In his doctoral work, Mr. Timura conducted fieldwork with key stakeholders (donors, NGOs, policy specialists, and researchers) responsible for the development and spread of international conflict management and conflict resolution expertise. Mr. Timura also completed graduate fieldwork on conservation and development issues in Central America.
Mr. Timura was a National Science Foundation predoctoral fellow at the University of Michigan from 1997 to 2002 and a Fulbright Scholar to the United Kingdom from 1996-1997, where he earned his MSc. in anthropology and ecology of development from the University College, London. Mr. Timura completed his B.A. in environmental studies at Denison University, where he graduated in the honors program, was elected to Phi Beta Kappa and was awarded Denison University President's Medal.
Representative engagements include:
- Advised private equity firm on the development of Environment, Social, and Governance (ESG) standards for fund portfolio companies, including development of a reporting process for same.*
- Represented major defense contractor in comprehensive review of ITAR agreement compliance, including review of sub-licensee activity and compliance, and amendment of agreements to remedy compliance issues, to incorporate Export Control Reform-required changes, and to ensure that the ITAR agreements authorized foreseeable business opportunities for the companies involved. Developed custom investigation and reporting software tools to support the investigation and remediation efforts that were nominated for the Financial Times' Most Innovative North American Law Firms 2015 Compliance & Technology Award.*
- Advised hedge fund on the development of an ESG policy, including support on benchmarking of Social and Governance policies for use in outreach to the management team of fund investments.*
- Counseled leading, U.S. company involved in lithium ion battery research, development and production on entry into defense and space systems markets, including development of ITAR compliance and licensing program.*
- Brokered comprehensive export-control agreement and procedures among U.S., Canadian, and European companies participating in R&D collaboration using shared IT and software development systems.*
- Developed integrated anti-corruption, international trade, and political risk diligence process for private equity firm acquisition of companies and other assets.*
- Teamed with in-house IT system and application developers at a major defense contractor to develop custom software to help manage ITAR-authorization requirements.*
- Represented Asian trading company in investigation and disclosure to DDTC for brokering registration and licensing violations. DDTC resolved matter with no charges or penalties.*
- Advised defense contractors operating under DDTC Consent Agreements on the development of investigation and corrective action management and reporting systems.*
- Represented non-U.S. firm in parallel BIS and DOJ investigations in company's role in exports of aircraft to country subject to comprehensive trade embargo.*
- Advised defense contractor on a series of commodity jurisdiction and classification requests of regularly exported products to obtain export classifications that would lessen export compliance burdens.*
- Developed monitoring and evaluation system for international NGO focused on rule of law training in several areas, including human trafficking, child and forced labor, and wildlife trafficking.*
- Represented chemicals manufacturing firm in export classification requests of nano-sized chemical compounds and analysis of potential controls on technology related to same.*
- Developed survey of ESG policies among top 10 private equity firms across asset classes to support updates and development of private equity firm policies.*
- Represented a Hong Kong-based business-to-business seller of electronic components in an export control investigation which resulted in no penalties and the first ever delisting of a company from the U.S. Government Entity List.*
- Developed international sanctions, export controls, AML, and anti-corruption policies and compliance procedures for international debit and credit card transaction service provider.*
- Represented non-U.S. investment manager in OFAC investigation and disclosure into investments that later became the subject of U.S. blocking under executive orders.
- Advised international petroleum refiner on development of anti-corruption, sanctions, and export control procedures.*
- Represented major U.S. aerospace firm in a global investigation and disclosure to DDTC regarding unauthorized access by non-U.S. persons to technical data stored in the company's enterprise resource planning software and systems. DDTC resolved the matter without charges or penalties.*
- Conducted expedited international trade compliance diligence to acquisitions of multiple engineering companies by semiconductor manufacturer.
- Counseled dozens of companies on export control and classification request requirements for products with cryptographic (i.e., encryption) capabilities.
- Represented global telecommunications and network service provider in investigation of exports of encryption-capable products and historical reporting failures. BIS resolved the matter without charges or penalties.*
- Represented global freight forwarding and logistics provider in a series of export controls and sanctions investigations involving services to countries under comprehensive trade and service embargoes.*
- Represented in telecommunication engineering firm in obtaining BIS licensing for the design and installation of telecommunications and data infrastructure in country subject to comprehensive sanctions.*
- Developed survey of potential national and international export control- and intellectual property-related 'regulatory takings' that could impact engineering firm's ability to transfer and patent its vanguard energy technology in the U.S. and other key international destinations.*
* Engagement occurred when affiliated with another law firm.
Mr. Timura is a frequent presenter to industry and academic audiences and is the author of several trade and academic press articles on International Trade Compliance and Policy Matters.
"Congress Seeks to Force (and Tie) President's Hand on Sanctions Through Passage of Significant New Law Codifying and Expanding U.S. Sanctions on Russia, North Korea, and Iran" Gibson, Dunn & Crutcher LLP Client Alert, July 2017.
"A Blockbuster Week in U.S. Sanctions," Gibson, Dunn & Crutcher LLP Client Alert, June 2017.
"Economic Sanctions Developments in the Early Trump Administration," Gibson, Dunn & Crutcher LLP Client Alert, June 2017.
"Competing Interests Weigh Against Broad Import Controls on Steel Imports After Section 232 Public Hearing," Gibson, Dunn & Crutcher LLP Client Alert, June 2017.
"Iran Sanctions Update – Status Quo So Far, Uncertainty Remains," Gibson, Dunn & Crutcher LLP Client Alert, May 2017.
"Mitigating Corruption Risk in Renewables," Project Finance International, April 2016.
"Remember to Comment on BIS' Cybersecurity Export Rule," Law 360, June 2015.
Contributor and Guest Editor, Special Issue on Negotiation Pedagogy, International Negotiation, Vol. 15(2) (2010).