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Kristina Arianina

Of Counsel

Washington, D.C.

Kristina represents companies and individuals in government investigations and commercial litigation. She regularly conducts internal investigations and counsels companies on compliance issues.

Kristina's practice focuses on the Foreign Corrupt Practices Act (FCPA), the False Claims Act (FCA), securities fraud, and violations of U.S. economic sanctions. She has represented companies and individuals in matters before the U.S. Department of Justice (DOJ), U.S. Securities and Exchange Commission (SEC), the Office of Foreign Assets Control (OFAC), and other government agencies.

Kristina is experienced in FCA matters, having worked extensively on qui tam and government initiated FCA cases. Her representations include defending a Medicare Advantage Plan against allegations of upcoding patient risk assessments as part of an alleged physician kickback scheme in violation of the Anti-Kickback Statute (AKS). She is currently representing a Fortune 500 company in a billion-dollar action alleging FCA violations in the context of the Superstorm Sandy recovery effort.

In addition, Kristina has monitorship experience. For over two years, she was part of a team that acted as Counsel to the Monitor in a DOJ-ordered monitorship of an auto-software maker related to the ‘Dieselgate’ investigation of devices designed and used to cheat on pollution emissions tests in violation of the Clean Air Act.

Kristina conducts internal investigations and compliance assessments for companies headquartered in the United States and abroad, represents clients in enforcement matters, and helps companies develop and implement compliance policies and strategies for their domestic and international operations. She also represents boards and audit committees following criminal matters.

Kristina has represented multinational corporations across the financial services, health care, technology, engineering, and manufacturing industries. She has led investigations and compliance reviews in the Middle East, China, and Europe. Kristina’s Russian and Ukrainian background contributes to the global nature of her practice.

Kristina maintains an active pro bono practice. She leads the firm’s collaboration with Public International Law & Policy Group on the Ukraine Accountability Initiative. While in law school, Kristina served as a student attorney at the law school’s Clinical Office, where she represented a father in a termination of parental rights case before the Maryland Court of Special Appeals, as well as interning at the Maryland Office of the Public Defender as a recipient of Maryland Public Interest Law Project Grant.

    • Representing boards and audit committees following criminal matters.
    • Representing a Fortune 500 company in a billion-dollar action alleging FCA violations in the context of the Superstorm Sandy recovery effort.
    • Defended a Medicare Advantage Plan in an FCA investigation, focusing on allegations of upcoding for patient risk assessments.
    • Assisted in the defense of Igor Danchenko in United States v. Danchenko in the Special Counsel Durham probe, which case resulted in a unanimous jury acquittal in the Eastern District of Virginia.
    • Was part of a team that acted as Counsel to the Monitor in a DOJ-ordered monitorship of an auto-software maker related to the ‘Dieselgate’ investigation by the DOJ of devices designed and used to cheat on pollution emissions tests in violation of the Clean Air Act.
    • Successfully defended against a temporary restraining order and a permanent injunction enabling a client to receive substantial funds.
    • Represented National Commercial Bank, Saudi Arabia’s largest bank, in defending a multi-year OFAC investigation of apparent violations of U.S. sanctions against Sudan and Syria.
    • Represented Habib Bank Limited, Pakistan’s largest bank, in liquidating its New York branch without further enforcement action by the Federal Reserve or the New York Department of Financial Services.
    • Represented a foreign bank in defending a multi-year OFAC investigation with the issuance of a private cautionary letter.
    • Conducted an internal investigation into bribery and kickback allegations relating to the acquisition by a U.S.-based public company of an entity in Asia.
    • Represented foreign financial institutions in investigations of potential violations of U.S. sanctions before the OFAC, the Department of Justice and other U.S. enforcement agencies and regulators.
    • Represented a foreign bank in a petition for delisting from the OFAC sanctions list.
    • Represented a major fluorochemicals manufacturer in regulatory and policy issues arising under Montreal Protocol on Substances That Deplete the Ozone Layer, including successful representation in Mexichem Fluor Inc. v. EPA, 866 F.3d 451 (D.C. Cir. 2017). The case was featured in Law360’s “Biggest Environmental Rulings of 2017.”
    • Represented foreign banking executives in suits filed in the federal court in New York involving federal and common law claims.
    • Represented a foreign entity in ICC arbitration of a multibillion-dollar dispute concerning breach of contract and negligence in a transportation infrastructure project in the Middle East.
    • Represented a U.S. company in UNCITRAL arbitration of a multibillion-dollar dispute concerning breach of contract and negligence in a transportation infrastructure project in Oceania.
    • Represented a prominent foreign bank in a high-profile U.S. multidistrict litigation.
    • Represented a foreign company in a defamation suit against a major U.S. newspaper.