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 and White Collar Defense and Investigations Practice Groups.
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 span economic sectors and range from start-ups to Global 500 companies.
Mr. Timura counsels clients on compliance with U.S. export controls (ITAR and EAR), economic sanctions, and foreign investment reviews and represents them before the departments of State (DDTC), Treasury (OFAC and CFIUS), Commerce (BIS), Homeland Security, and Justice in voluntary and directed disclosures, civil and criminal enforcement actions and investment reviews. Working with in-house counsel, boards, and other business leads, he helps to identify and leverage existing business processes to integrate international trade compliance, and CSR-related data gathering, analysis, investigation, and reporting throughout client business operations. In M&A and other transactions, he conducts expedited diligence on international trade compliance and ESG issues and supports business and compliance teams as they work to spin off or integrate business operations in new organizations.
Mr. Timura also assists clients working with emerging and foundational technologies in the development of effective international trade compliance-, export control licensing-, and CSR-strategies to support global R&D, supply chain, and customer bases.
On a pro bono basis, Mr. Timura assists clients with immigration issues, and works with 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 serves on the ABA’s Export Controls and Economic Sanctions Committee and was appointed to Department of Commerce’s Regulations and Procedures Technical Advisory Committee in 2022.
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 was a National Science Foundation Pre-Doctoral Fellow at the University of Michigan from 1997 to 2002, where he earned a Ph.D. in Cultural Anthropology, 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:
- Counseled international telecommunications services and equipment provider on compliance with Department of Commerce Denial Order against ZTE and represented client in briefings before Commerce and other U.S. government agencies on collateral impacts and need for expedited authorizations to support client’s services worldwide.
- Represented international marine insurer in investigation and disclosure to OFAC of potential violations involving payments to insureds in countries subject to U.S. sanctions.
- Advised major international manufacturer of oil and gas development and production equipment on Section 232 investigation on aluminum and steel imports and on compliance with U.S. export controls and sanctions. Worked with same to identify and mitigate potential collateral impacts of U.S. sanctions under CAATSA and other proposed sanctions.
- Worked with private equity firm to map sensitive technologies owned and used by portfolio companies and to develop trade compliance procedures to better protect same in advance of potential review by CFIUS.
- Supported international telecommunications providers with compliance with U.S. sanctions and export controls when providing services to customers located in countries subject to U.S. sanctions.
- Advised publicly traded companies on Iran-related disclosure requirements and other disclosures regarding potential sanctions and export controls liability.
- Represented international automaker in Department of Commerce Section 232 Questionnaire process.
- Counseled semiconductor manufacturer under criminal investigation for exports of ITAR-controlled satellite components.
- Advised major Asian trading company on compliance with U.S. sanctions and export controls while operating in countries subject to comprehensive U.S. sanctions.
- Brokered comprehensive export-control agreement and procedures among U.S., Canadian, and European companies participating in aerospace R&D collaboration using shared IT and software development systems.
- Represented former CEO of company facing potential criminal and civil enforcement action for its failure to develop adequate export control compliance policies and procedures.
- Advised international provider of nuclear enrichment services on potential commercial impacts of Section 232 remedies to be developed based on Department of Commerce investigation.
- 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.
- Developed integrated anti-corruption, international trade, and political risk diligence process for multiple private equity and other investment firms.
- Advised several top 10 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.
- 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.
- 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.*
- 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. The monitoring and evaluation tools were nominated for the 2017 Financial Times’ innovation in “Rule of Law and Access to Justice Award.”*
- 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.
- Represented chemicals manufacturing firm in export classification requests of nano-sized chemical compounds and analysis of potential controls on technology related to same.
- 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.
- 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 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.
Recent Speaking Engagements
- “How ESG Should Inform International Trade Compliance, and Vice Versa,” Gibson Dunn, September 2022, Webinar.
- “Prospects of Russian Sanctions and Possible Measures by Korean Companies,” Korea International Trade Association, May 2022, Webinar.
- “Solving for Third Party Screening, Diligence, and Risk Management in the Context of Crisis, Integration, and Change,” Ankura, Gibson Dunn, and Descartes, May 2022, Webinar.
- “Implementation and Compliance Workshop for Representatives of the Taiwan Economy On Proliferation-Sensitive Ballistic Missile Technologies,” CRDF Global, February 2022, Virtual Workshop.
- “The World Reacts to the Crisis in Ukraine: Sanctions and Export Controls Imposed by the U.S., the EU, the UK, Australia, Japan and Other Countries,” March 2022 Gibson Dunn Webcast.
- “Doing Aerospace M&A Deals in 2020,” Aviation Week A&D Mergers and Acquisitions Conference, November 2020, Webcast.
- “Chinese Companies on the Entity List: How the Trump Administration Is Weaponizing This Powerful Enforcement Tool in New Ways,” October 2020, Gibson Dunn Webcast.
- “Implementation and Compliance Workshop for Representatives of the Taiwan Economy On Proliferation-Sensitive Ballistic Missile Technologies,” CRDF Global, January 2020, Taiwan.
- “Accessories Council Business Workshop 2019,” November 2019, NYC.
- “AI and Big Data Legal Developments,” September 2019, Gibson Dunn Webcast.
- “Practical Guidance on Managing New Foreign Investment Review Requirements and Export Controls on Emerging Technologies,” Association of Corporate Counsel National Capital Region, July 10, 2019, Tysons Corner, Virginia.
- “Getting Deals Done in the 4th Industrial Revolution,” Products with Minds of Their Own 2019: AI and Big Data Legal Developments and Considerations, Gibson Dunn Workshop, April 24, 2019, Palo Alto, CA.
- “U.S. Economic and Trade Sanctions Against Venezuela – the Outlook for 2018,” March 2018, Gibson Dunn Webcast.
- “New Controls on Emerging Technologies Released, While U.S. Commerce Department Comes Under Fire for Delay,” Gibson, Dunn & Crutcher LLP Client Alert, October 2020
- “U.S. Export Controls: The Future of Disruptive Technologies,” C. Timura, J.A. Lee, R. Pratt and S. Toussaint, NATO Legal Gazette, Issue 41
- “2020 Mid-Year Sanctions and Export Controls Update,” Gibson, Dunn & Crutcher LLP Client Alert, August 2020
- “Trump Administration Increases Pressure on Huawei with New Export Controls That Will Limit Its Access to Semiconductors Produced with U.S. Software and Technology,” Gibson, Dunn & Crutcher LLP Client Alert, May 2020
- “U.S. Moves to Tighten Export Controls on China and other Jurisdictions with Policies of Civil-Military Fusion,” Gibson, Dunn & Crutcher LLP Client Alert, May 2020
- “COVID-19 & International Trade – Nation-State Responses to a Global Pandemic,” Gibson, Dunn & Crutcher LLP Client Alert, April 2020
- “2019 Artificial Intelligence and Automated Systems Annual Legal Review,” Gibson, Dunn & Crutcher LLP Client Alert, February 2020
- “2019 Year-End Sanctions Update,” Gibson, Dunn & Crutcher LLP Client Alert, January 2020
- “U.S. Congress Passes The Hong Kong Human Rights and Democracy Act of 2019; Awaiting Presidential Signature,” Gibson, Dunn & Crutcher LLP Client Alert, November 2019
- “New U.S. Sanctions Targeting Turkish Government in Response to Military Operations in Syria,” Gibson, Dunn & Crutcher LLP Client Alert, October 2019
- “Proposed CFIUS Regulations: The U.S. Remains Open for Business … but Read the Fine Print,” Gibson, Dunn & Crutcher LLP Client Alert, September 2019
- “New U.S. Sanctions Targeting Venezuelan Government,” Gibson, Dunn & Crutcher LLP Client Alert, August 2019
- “Citing a National Emergency, the Trump Administration Moves to Secure U.S. Information and Communications Technology and Service Infrastructure,” Gibson, Dunn & Crutcher LLP Client Alert, May 2019
- “Iran Steps Back from Nuclear Deal as Trump Administration Increases Sanctions Pressure,” Gibson, Dunn & Crutcher LLP Client Alert, May 2019
- “President Trump Ramps Up Cuba Sanctions Changes — Allows Litigation Against Non-U.S. Companies Conducting Business in Cuba,” Gibson, Dunn & Crutcher LLP Client Alert, May 2019
- “Venezuela Update: the Trump Administration Imposes Oil Sanctions to Effect Regime Change,” Gibson, Dunn & Crutcher LLP Client Alert, January 2019
- “Iran Sanctions 2.0: The Trump Administration Completes Its Abandonment of the Iran Nuclear Agreement,” Gibson, Dunn & Crutcher LLP Client Alert, November 2018.
- “CFIUS Reform,” Briefing Papers Second Series, Timura, Christopher T., Lee, Judith A., Fernandez, Jose W., Connor, Stephanie L., Pratt, R.L., Thomson Reuters, October 2018.
- “CFIUS Reform: Our Analysis,” Gibson, Dunn & Crutcher LLP Client Alert, August 2018.
- “Trump Administration Imposes Unprecedented Russia Sanctions,” Gibson, Dunn & Crutcher LLP Client Alert, April 2018.
- “2017 Year-End Sanctions Update,” Gibson, Dunn & Crutcher LLP Client Alert, February 2018.
- “U.S. and International Policy Convergence Brings Supply Chain Diligence on Labor Trafficking to the Fore,” Gibson, Dunn & Crutcher LLP Client Alert, November 2017.
- “Trump Administration Implements Congressionally Mandated Russia Sanctions – Significant Presidential Discretion Remains,” Gibson, Dunn & Crutcher LLP Client Alert, November 2017.
- “Cuba Sanctions: The Trump Administration Takes Steps to Implement Rollback of Obama Era Sanctions Relief,” Gibson, Dunn & Crutcher LLP Client Alert, November 2017.
- “Trump Decertifies the Iran Deal, Creating Both New Uncertainties and Potentially Unexpected Clarity,” Gibson, Dunn & Crutcher LLP Client Alert, October 2017.
- “In Latest Salvo, the Trump Administration Pressures Non-U.S. Companies and Persons to Cut Financial and Business Ties with North Korea,” Gibson, Dunn & Crutcher LLP Client Alert, September 2017.
- “President Trump Issues New Sanctions Targeting Certain Activities of PdVSA and the Government of Venezuela,” Gibson, Dunn & Crutcher LLP Client Alert, September 2017.
- “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).