Christine Daya's practice focuses on a variety of laws and policy at the intersection of national security and global trade. For over a decade, Christine has served as a trusted advisor to major U.S. and non-U.S. multinational clients on foreign direct investment (CFIUS), economic sanctions (OFAC), supply chain risk management (CBP), and congressional investigations.
Christine develops a deep understanding of her clients’ business and draws on her strong knowledge of relevant laws and regulations in rapidly-changing fields to advise on challenging, high-stakes, government-facing matters. She represents clients in a wide range of industries, including financial services, emerging technology, consumer goods, pharmaceuticals, energy, manufacturing, insurance, real estate, telecommunications, and others.
For hundreds of cross-border investments, Christine has advised on the requirement or recommendation to file with CFIUS and on the allocation of CFIUS risk in transaction documents. She has effectively and efficiently cleared the CFIUS process for dozens of clients and negotiated national security agreements if needed to obtain CFIUS clearance.
Christine also has substantial experience with sanctions matters before the Office of Foreign Assets Control (OFAC). She advises clients on primary and secondary sanctions compliance and risk, designs and implements compliance policies and procedures, leads complex internal investigations related to potential violations, and has had considerable success with the submission of voluntary self-disclosures and license applications to OFAC.
Additionally, Christine counsels clients on global supply chain risk management and forced labor legal liability. She works with clients to gain visibility into their supply chains, identify and remedy risk, and respond to CBP enforcement of the Uyghur Forced Labor Prevention Act (UFLPA).
Finally, Christine has represented companies and individuals in high-profile congressional investigations, working with clients on scoping of requests, witness preparation, strategy development, and document production.
Examples of representations include:
- European publicly traded energy company to obtain CFIUS clearance in connection with $8 billion acquisition
- Middle Eastern sovereign wealth funds on CFIUS compliance in connection with various U.S.-based investments
- Venture capital arms of multiple Japanese and South Korean conglomerates to obtain CFIUS clearance in connection with strategic U.S. investments in critical technology and infrastructure
- Publicly traded U.K. entity in its acquisition of a sensitive U.S. government contractor to obtain CFIUS clearance and mitigate Foreign Ownership, Control, and Influence (FOCI)
- Major U.S. port authority on concession of strategic port to foreign ports operator to obtain CFIUS clearance
- South Korean biopharmaceutical company in its acquisition of a U.S. CDMO to obtain CFIUS clearance
- Canadian private equity firm on CFIUS compliance in connection with multiple acquisitions of U.S. critical infrastructure
- Multiple multinational insurance companies on sanctions compliance, internal investigations, voluntary self-disclosures, and license applications under every major U.S. sanctions regime
- Major U.S. government contractor to design and implement sanctions policies and procedures, with a focus on cyber-related sanctions
- Publicly traded U.S. apparel company to survey its supply chain for forced labor risk in conjunction with multiple third-party vendors, and respond to CBP enforcement under the UFLPA
- Publicly traded U.S. pharmaceutical company before the Senate Finance Committee in a drug pricing investigation
- J.D., University of Maryland School of Law
- B.A., International Relations, Economics, College of William and Mary
summa cum laude
- Her Pro Bono work has earned Christine recognition from the firm and outside organizations, and has helped improve the situation of immigrants and non-profit organizations. Christine is engaged in multiple DLA Piper initiatives, and serves on the firm's Leadership Alliance for Women.
- New regulations reinforce CFIUS's expanded role with respect to foreign investments in the United States (January 2020)
- Treasury Department proposes regulations comprehensively implementing FIRRMA and reforming CFIUS national security review (September 2019)
- CFIUS pilot program mandates declarations for certain non-controlling investments in critical technologies (October 2018)
- FIRRMA, reforming CFIUS process, is signed into law (August 2018)
- Congress finalizes CFIUS reform bill to broaden national security reviews of foreign investments (July 2018)
- Trade compliance strategies for Chinese companies: Managing the risks of US ‘Extraterritorial Jurisdiction’, 21 September 2023
- The new era of investment in China and what it means for your business, 23 August 2023
- General Counsel Dinner Series, 8 March 2023
- AAP 2022 Virtual Door Knock Series: Increasing US Outbound Investment Screening for China, 7 October 2022
- Quoted, "U.S. Exempts Earthquake Aid to Syria From Sanctions," The Wall Street Journal, February 10, 2023
- Quoted, "National security strategy unveiled, and outbound regime is referenced," Foreign Investment Watch, October 19, 2022
- Quoted, "Chinese Investors Still Leery of U.S. Acquisitions After Oversight Changes," The Wall Street Journal, August 2, 2022
Before her legal career, Christine was a senior associate at a Big Four accounting firm, where she worked as a consultant in its public sector practice. In law school, she achieved a strong academic record and gained legal experience working as law clerk at the Department of Homeland Security and the National Association of the Deaf.
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