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Christian advises clients on a broad range of transactional, regulatory, and enforcement matters. His experience includes advising major companies and corporate officers in connection with U.S. and global economic sanctions, the Foreign Corrupt Practices Act (FCPA), the Committee on Foreign Investment in the United States (CFIUS), and Bank Secrecy Act (BSA) / anti-money laundering (AML) regulations. As Cadwalader’s financial crime specialist for capital markets transactions, Christian regularly helps clients diligence vendors, counterparties, and M&A targets. Super Lawyers has named Christian as a New York Metro Rising Star every year since 2020.
Representative regulatory matters:
- Served an extended secondment to Barclays as Acting Director of Financial Crime Legal, to replace the outgoing director.
- Led a global investment bank’s FCPA diligence for M&A and IPO transactions; counseled the managing directors on key findings.
- Developed BSA and OFAC compliance policies and procedures for an investment bank, several broker-dealers, a family office, an insurance company, and several cryptocurrency businesses.
- Advised a fintech firm on anti-money laundering and sanctions compliance for cross-border financial services offerings.
- Provided regulatory advice to the first major U.S. investment bank to offer wealth clients access to a Bitcoin fund.
Christian has extensive experience facing regulators including the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodities Futures Trading Commission (CFTC), the Federal Reserve, the Office of the Comptroller of the Currency (OCC), FINRA, FinCEN, and the U.S. Treasury Office of Foreign Assets Control (OFAC).
Representative investigations and enforcement matters:
- Conducted an internal investigation to assess a U.S. multinational company’s compliance with the FCPA.
- Represented a global retail executive in connection with a DOJ investigation of compliance with OFAC sanctions.
- Advised financial institutions investigating compliance with OFAC regulations and prepared voluntary self-disclosures.
- Represented a real estate investment trust facing an SEC investigation of director independence.
- Counseled a non-U.S. headquartered broker-dealer in responding to FINRA examination findings alleging AML and sanctions violations.
- Served on monitorship team for the first-ever Drug Enforcement Agency (DEA) monitorship imposed on a pharmaceutical distributor.
- Represented a merger target in a CFIUS review.
- Represented a bank’s director of compliance as a witness in lawsuits against the bank.
- Represented a software developer under investigation by the DOJ and CFTC in connection with offshore binary options trading.
- Represented a global toll road operator challenging the lawfulness of a competitor’s financial proposal in a $9 billion state procurement; argued the case at trial. See, In the Petition of Capital Express Mobility Partners, Montgomery Cir. Ct. (Md.) (C-15-CV-22-001808).
Prior to joining Cadwalader, Christian lived and worked for eight years in Europe, Central Asia, and the Middle East. He advised the International Monetary Fund (IMF) Legal Department on the effectiveness of anti-money laundering law in 153 jurisdictions. He served in the DOJ’s Money Laundering and Asset Recovery Section (MLARS). He also served as U.S. Department of State secondee to the Organization for Security and Cooperation in Europe (OSCE) in Vienna, Austria. In that role he counseled the governments of 53 Member States, and headed OSCE delegations to the Paris-based Financial Action Task Force (FATF) and the United Nations Office on Drugs and Crime (UNODC).
