Christopher D. Grigg

/My focus

For more than 15 years as a federal prosecutor, including 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 three areas.

INTERNATIONAL TRADE, EXPORT CONTROLS, ECONOMIC SANCTIONS, AND NATIONAL SECURITY INVESTIGATIONS

I advise and counsel clients of all sizes on export controls and sanctions matters involving transactions, goods, software, 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 an export enforcement task force comprised of more than twenty federal agencies, 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 deep experience in investigations spanning the globe. Export controls and sanctions laws are key features of US national security and foreign policy, and businesses know that violations carry potentially catastrophic consequences. I work with clients to develop practical solutions and apply real-world lessons learned to improve compliance, mitigate risk, navigate government inquiries, and defend against enforcement actions.

INTERNAL AND GOVERNMENT INVESTIGATIONS

Whether undertaking internal investigations of suspected wrongdoing or responding to subpoenas or other government inquiries, clients increasingly need experienced counsel who understand government and can anticipate emerging regulatory and enforcement risk. I have led and supervised hundreds of investigations at the forefront of the government’s national enforcement priorities in matters involving: the FBI; the Commerce Department’s Bureau of Industry and Security; the Department of Justice (DOJ), including the Counterintelligence and Export Control Section and other components of DOJ’s National Security Division; the Department of Homeland Security, including US Customs and Border Protection and DHS’s Homeland Security Investigations; the IRS; NASA; and the Department of Defense. I apply my years of experience managing complex federal investigations and prosecutions to help clients weigh the potential costs and benefits of voluntary disclosure, cooperation, and settlement against a constantly evolving business environment and shifting government enforcement priorities.

LITIGATION AND TRIALS

Clients facing litigation and potential trials must quickly implement strategies that minimize risk, effectively manage costs, and maximize opportunities for favorable outcomes both before trial and after. I leverage more than two decades of experience preparing and taking civil and criminal cases to trial to help clients succeed. 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 in high-stakes litigation.

/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

The federal government continues to evolve rapidly while global economies strive for stability and growth. The need for experienced counsel to navigate compliance and enforcement issues has never been greater. As state legislators and attorneys general take increasingly far-reaching action, federal agencies are shifting priorities and ramping up sanctions and trade enforcement efforts in pursuit of national policy objectives, especially as competition from China and Russia intensifies. Businesses adapting to the rapidly evolving economic and regulatory environment, especially those in the semiconductor, advanced computing, and artificial intelligence industries, must continue to invest in compliance to help protect against enforcement risk.

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