Christopher D. Grigg

/My focus

For more than 15 years as a federal prosecutor, including in my most recent role as Chief of the National Security Division at the US Attorney’s Office in Los Angeles, I led and supervised hundreds of investigations of suspected export and sanctions violations, fraud, money laundering, trade-secret theft, economic espionage, cybercrime, and terrorism. I also managed numerous complex domestic and international investigations involving counterintelligence, export-control, and sanctions-driven efforts to combat foreign aggression, foreign malign influence, cyber intrusions, and identity theft. I have been a litigation and trial lawyer for more than 20 years and bring my wealth of experience and insight to bear helping clients navigate the world around them. My practice focuses on four areas.

Internal and Government Investigations

Whether undertaking internal investigations of suspected wrongdoing or seeking guidance in addressing subpoenas or other government inquiries or allegations, clients increasingly need experienced counsel who understand government and can anticipate emerging regulatory and enforcement risk. I offer unique insights and apply lessons learned from my years of experience as a federal prosecutor leading matters at the forefront of the government’s national enforcement priorities. I have extensive experience in matters involving: the FBI; the Commerce Department’s Bureau of Industry and Security; the Counterintelligence and Export Control Section and other components of the Justice Department’s National Security Division; the Department of Homeland Security (DHS), including US Customs and Border Protection and DHS’s Homeland Security Investigations; the IRS; NASA; and the Department of Defense. Clients find my experience managing complex federal investigations and prosecutions particularly valuable, especially when weighing the potential costs and benefits of voluntary disclosure, cooperation, and settlement against a constantly evolving business environment and shifting government enforcement priorities.

International Trade, Export Controls, Economic Sanctions, and Cyber Investigations

I assist clients with export control and sanctions matters involving goods and technology regulated by the Commerce Department’s Bureau of Industry and Security, the Treasury Department’s Office of Foreign Assets Control, and the State Department’s Directorate of Defense Trade Controls. Throughout my time as a federal prosecutor, including several years overseeing the Los Angeles US Attorney’s Office’s Export and Anti-proliferation Global Law Enforcement Task Force, which leverages the authorities and capabilities of over twenty federal agencies to investigate and prosecute violations of export and trade sanctions laws, I led and supervised investigations involving violations of the Export Administration Regulations, the International Traffic in Arms Regulations, the Iranian Transactions and Sanctions Regulations, the Foreign Trade Regulations, the Export Control Reform Act, the Arms Export Control Act, and the International Emergency Economic Powers Act.

Clients directly benefit from my experience in investigations spanning the globe, including partnering with foreign officials to obtain records and interview witnesses and victims. Many of my cases have featured international businesses and academic institutions as perpetrators, victims, and witnesses. And I’ve led and supervised export and cyber investigations leveraging mutual legal assistance treaties to pursue evidence in dozens of countries around the world.

The illicit conduct in these and similar cases frequently jeopardized US companies’ most valuable intellectual property assets and data holdings, the compromise of which threatened the IP holders’ bottom line and, in some cases, their very existence. I have extensive experience investigating how such compromises happen and identifying weaknesses in victim companies’ defenses.

Litigation and Trials

Clients facing litigation and the prospect of trial must quickly implement strategies that minimize risk, effectively manage costs, and maximize opportunities for favorable outcomes both before trial and after. I assist clients by leveraging more than two decades of experience preparing and taking civil and criminal cases to trial. In both my own cases, and later in virtually every national security matter prosecuted in Los Angeles for nearly a decade, I developed, implemented, and supervised litigation tactics and strategies to manage risk, reach settlements, admit evidence, and persuade judges and juries to accept my client’s view of the facts and the law. My experience helps me advocate for clients’ interests in ways that are engineered to succeed in courtrooms and administrative tribunals.

Global Compliance and Engagement with Government Authorities

Robust compliance and well-considered interaction with government regulators are vital for success in today’s increasingly complex global economy. I draw on my extensive litigation and law enforcement experience to help clients diagnose compliance needs, meaningfully engage with regulators, and develop and improve best practices as they seek to compete in the global business world.

/Representative experience

• Supervised the investigation and prosecution of an international money laundering network in United States v. Zangakani, et al., responsible for executing transactions on behalf of Iran exceeding $750,000,000, including the purchase of oil tankers for state-owned enterprises, in violation of US sanctions.
• Led the investigation and successful prosecution in United States v. Zhang, et al., involving a transnational corporation that reverse-engineered US export-controlled microchips and sold the technology to Chinese military research institutes by securing government contracts there through bribery.
• Led and supervised multiple investigations and prosecutions of faculty and students working in university research laboratories to develop, test, and ultimately steal sensitive technologies, including the investigation and prosecution of United States v. Shih, et al., which resulted in the successful trial of a former defense contractor and university professor who ran an elaborate scheme to establish a foundry that would manufacture specialized semiconductor chips used in numerous military applications for China, including for a specific Chinese military research institute.
• Supervised the investigations and prosecutions of state-sponsored hacking targeting prominent US defense industry contractors in United States v. Su Bin (involving the Chinese military’s hacking and theft of sensitive data from Boeing and others) and entertainment and financial firms in United States v. Park (involving North Korea’s hacking of Sony Pictures Entertainment, global release of the WannaCry malware, large-scale cybertheft, and laundering of funds from international banks, and crypto-enabled fraud).
• Supported and supervised the successful prosecutions and jury trials of a DDOS-for-hire distributor in United States v. Gatrel, an iPhone unlocking scam in United States v. Khudaverdyan, and a would-be terrorist attacker in United States v. Domingo.
• Led the investigation and resulting prosecutions arising from the December 2015 San Bernardino terrorist attack, including the prosecution of United States v. Marquez, involving the individual who provided two assault weapons used in the attack, and United States v. Shareef, involving a family member of the attackers who destroyed key evidence in the case.
• Successfully tried and defended on appeal United States v. Guo, et al., involving illicit smuggling of export-controlled thermal imaging cameras to China.
• Served as one of three prosecutors who successfully prosecuted the first material support case in Central District history.
• Led investigations and prosecutions of global procurement networks employing a variety of shell companies, logistic firms, financiers, and other business entities to export, re-export, and transship commodities from the United States through the UAE and other transshipment nodes to destinations in Northern Africa, the Middle East, Russia, Asia, and Southeast Asia.

Trainings, presentations, and speaking engagements

• For several years, the Justice Department’s National Security Division and Export Control Section (CES) leadership have invited Chris to speak on complex issues panels offered at national training events for attorneys with DOJ, the FBI, and the general counsels’ offices of a variety of intelligence agencies
• Led trainings for federal prosecutors and law enforcement professionals around the country on topics including national security investigations, export enforcement, and crisis response
• The National Advocacy Center, lecturer and presenter on crisis response, complex issues in counterintelligence and export control cases, and terrorism investigations and prosecutions
• University of Southern California Gould School of Law, Counterterrorism, Privacy, and Civil Liberties (LLM), Adjunct Lecturer in Law, Fall 2022
• The Gulf Cooperation Council, Saudi Arabia, Disrupting an International Money-Laundering Scheme: Lessons Learned, presenter June 2022
• Pepperdine Law School, Criminal Cyber Law & Policy, guest lecturer March 2019 and October 2020
• UCLA Law School, Comparative Counterterrorism Law and Policy, guest lecturer February 2018
• The International Institute for Justice and the Rule of Law, Malta, Beyond Foreign Terrorist Fighters, presenter June 2017

/Looking ahead

As DOJ priorities continue to evolve and global economies strive for stability and growth, the need for experienced counsel to navigate compliance and enforcement issues has never been greater. Federal agencies likely will continue to ramp up their focus on white-collar crime and pursue sanctions and trade enforcement as tools of national policy, especially as competition from China and Russia intensifies. The federal government and many state attorneys general will increasingly scrutinize and seek to regulate digital assets and markets, emerging DeFi technologies, cybersecurity practices, and efforts to protect digital privacy. Businesses are correctly focusing on identifying and resolving new compliance challenges, but they must also look around the next corner because enforcement efforts are sure to follow.

Prior experience

• United States Attorney’s Office for the Central District of California (Los Angeles), Assistant United States Attorney, November 2007–December 2022
  • Chief, National Security Division, March 2020–December 2022
  • Chief, Terrorism and Export Crimes Section, August 2015–March 2020
  • Deputy Chief, Terrorism and Export Crimes Section, March 2013–August 2015
• Los Angeles County District Attorney’s Office, Deputy District Attorney, January 2005–November 2007
• Prior to government service, Chris was in private practice at a California firm (2002–2004).
• While his classmates prepared for the bar, Chris joined the military, where he was the distinguished honor graduate for his class at the United States Army’s Ranger School and served as a team leader in the Army’s 75th Ranger Regiment (1997–2001).

/Insights

• “Managing Export Enforcement Visits: Before, During and After the Knock on the Door,” Massachusetts Export Center, November 3, 2023
• “White Collar Trends in 2023: A Year in Review,” ABA White Collar Committee, October 17, 2023
• “Russia Sanctions and Export Controls Update: A Year Later,” Mass Export Control Enforcement Webinar, March 24, 2023