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Guillermo Christensen

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Guillermo Christensen is the Office Managing Partner of Ice Miller’s Washington DC Office. 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. As a partner in Ice Miller’s Data Security and Privacy and White Collar Defense Groups, Guillermo integrates his international investigation experience and technical knowledge to deal with the challenges of 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. Drawing on his national security background, Guillermo also 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 regularly 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 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.

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