Cristina K. Lunders

Sr. Associate

Fulbright & Jaworski LLP

Cristina K. Lunders


T:+1 713 651 5619

F:+1 713 651 5246

Cristina Lunders joined Norton Rose Fulbright's Houston office in 2006 with significant experience in assisting clients with diverse regulatory and governmental investigation needs, including investigations, compliance, and due diligence. 
Cristina has worked with both public and private clients in governmental and internal investigations (including Foreign Corrupt Practices Act ("FCPA"), financial fraud, and employee misconduct investigations). Her investigations and litigation matters have often involved managing large document collections, reviews, and analyses, interviewing of key personnel and presenting findings to internal and governmental bodies. 
In the compliance area, Cristina has drafted and implemented new and updated policies and procedures, provided relevant training to boards and other employees and conducted risk assessments and audits. Her transactional due diligence work has involved a variety of clients and situations including M&A transactions, agents and joint venture partners.
For 20 months from 2010 through 2012, Cristina was seconded to the world's largest natural resources company and gained valuable insight from the client's perspective.  She is aware of and fully understands the challenges that affect in-house compliance groups. During her secondment, Cristina led internal investigations, performed due diligence on transactions, conducted anti-corruption risk assessments and drafted and implemented anti-corruption policies and procedures. She also trained thousands of employees worldwide on international anti-corruption laws.
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  • Education

    2006 - J.D. with honors, The University of Texas School of Law
    2003 - B.A., summa cum laude, History, Political Science and Anthropology, University of Idaho

    Cristina is admitted to practice law in Texas State Court and in Federal Court in the Southern and Eastern Districts of Texas.

  • Representative experience
    • Drafted anti-corruption policies, procedures, guidelines, and template forms for US and non-US public and private companies in diverse industries including Energy & Infrastructure; Transport; Technology, and others; also prepared and conducted training implementing new policies and procedures for such companies.
    • Represented a former employee of a US-based oil and gas company in an SEC and DOJ investigation for alleged corrupt activity in Africa.
    • Represented two multinational oilfield services companies in FCPA investigations.
    • Represented an oil and gas company in a Congressional Committee inquiry.
    • Represented a technology company in due diligence and compliance assessment for acquisition of a Saudi lighting company.
    • Represented a drilling company in conducting due diligence into a joint venture partner and logistics provider.
    • Represented a distributor acquiring a competitor with worldwide operations, including a joint venture in Nigeria and multiple foreign agents.
    • Represented an oil and gas company in conducting due diligence into an international agent located in the Middle East.
    • Represented an oil and gas company in conducting due diligence into agents located in Pakistan, Venezuela, and Algeria.
    • Represented a publicly traded, multinational oilfield services company in due diligence for two major acquisitions involving substantial operations in Latin America, the Middle East and Europe.
    • Provided a risk assessment of a global oil and gas services company's foreign operations, which included gauging worldwide anticorruption risks and advising on a centralized compliance program.
    • Provided a risk assessment of a global oil and gas product supplier, including gauging worldwide anticorruption risks and making recommendations for improvement for an already sophisticated compliance program. 
    • As a young associate, managed the document review of a major internal and government investigation with over 3 million documents reviewed by a team of hundreds of lawyers.  Also participated in interviews of key witnesses and presented findings to government agencies.
    • Led internal investigation into fraud and potential misuse of company assets.
    • Led internal investigation into potential misconduct of a corporate officer during an audit.
    • Litigated several cases, including obtaining judgment awarding attorney fees to client after previously winning judgment dismissing all of the plaintiff's multi-million dollar claims against her client; participating in multi-week trial in Hidalgo County, assisted with preparation of exhibits, deposition cuts, and expert cross-examination; participated as lead counsel in several mediations; deposing fact and expert witnesses in personal injury and commercial cases; and removing a significant number of cases from actions filed in Texas and Louisiana state courts related to mass product liability claims.
  • Professional activities
    • Councilmember, Houston Bar Association International
    • Secretary, Houston Young Lawyers Foundation Board of Trustees
    • Houston Bar Association Speaker's Bureau
    • The State Bar of Texas
    • Texas Young Lawyers Association
    • Texas Women Lawyers
  • Speaking engagements
    • Speaker, "FCPA and M&As:  How to Get Your Target Acquisition-Ready," ACI's 8th Houston FCPA Boot Camp Event, American Conference Institute, Jan. 22-23, 2014
    • Speaker, "Introduction to the US Foreign Corrupt Practices Act," Rice University, Dec. 13, 2013
  • Publications
    • Co-author with Marsha Gerber and Christian Menefee, "SEC issues new Conflict Minerals Guidance post NAM,"Norton Rose Fulbright - Legal update, May 8, 2014
    • Co-author with Marsha Gerber and Christian Menefee, "DC Circuit vacates part of Conflict Minerals rule,"Norton Rose Fulbright - Legal update, April 22, 2014
    • Co-author with Marsha Gerber and Christian Menefee, "SEC issues new guidance on conflict mineral rule," Norton Rose Fulbright - Legal Update, April 11, 2014
    • Co-Author with Richard Smith, Marsha Gerber, Paul Sumilas, and Ilana Sinkin, "Cutting the ties that bind," Norton Rose Fulbright - Legal Update, March 27, 2014
    • Co-Author with Richard Smith, Marsha Gerber and Samuel August, "Diebold pays $48 million to resolve bribery allegations," Norton Rose Fulbright - Legal Update, Oct. 24, 2013
    • Co-Author with Marsha Gerber, Sam Eastwood, and Ruth Cowley, "Disclosure provisions in the extractive industries,"Norton Rose Fulbright - Legal Update, May 2013
    • Co-author, "U.S. and EU Disclosure Requirements for the Extractive Industries," Fulbright Briefing, May 15, 2013
    • Co-author, "4 Takeaways From 2nd Highest FCPA Penalty," Law360, May 14, 2013
    • Co-author, "Lessons From Philips FCPA Settlement Over Polish Bribes," Law360, May 7, 2013
    • Co-author, "In SEC's First Ever FCPA Non-Prosecution Agreement, SEC and DOJ Enter Into Parallel Agreements with Ralph Lauren Corporation; Total of $1.6 Million in Fines and Penalties," Fulbright Alert, April 24, 2013
    • Co-author, "Second Highest FCPA Civil Penalty Handed Down for Siemens Executive," Fulbright Alert, April 18, 2013
    • Co-author, "In first corporate FCPA enforcement action of 2013, Koninklijke Philips Electronics N.V. enters into administrative settlement with the SEC," Fulbright Alert, April 10, 2013
    • Co-author, "Four former Bizjet employees charged for FCPA violations, Two plead guilty," Fulbright Briefing, April 9, 2013
    • Co-author with Guy Singer, Marsha Z. Gerber and Kimberly S. Walker, "DOJ and SEC Settlements with Daimler Highlight Increased Fine and Imposition of Monitor for FCPA Violations," Fulbright & Jaworski L.L.P., April 2, 2010
    • Co-author with Elaine L. Lawson and Marsha Z. Gerber, "To Report Or Not To Report: Considerations in Determining Whether to Voluntarily Disclose FCPA Violations," The Review of Securities & Commodities Regulation, February 17, 2010
    • Co-author with Richard Smith, John E. Kelly and Kimberly Walker, "DOJ Launches the Largest Single Investigation and Prosecution Action Against Individuals in the History of the FCPA," Fulbright & Jaworski L.L.P. Briefing, January 20, 2010
    • Co-author with Richard Smith, John E. Kelly and Kimberly Walker, "Increased International Anti-Corruption Enforcement Highlights in Fine Imposed by German Authorities," Fulbright & Jaworski L.L.P. Briefing, December 18, 2009
    • Co-author with Richard Smith, Marsha Z. Gerber and Kimberly Walker, "Individual Enforcement and International Cooperation Highlighted in FCPA Guilty Plea," Fulbright & Jaworski L.L.P. Briefing, September 8, 2009
    • Co-author with Marsha Z. Gerber and Esther Nelson, "Dealing With Suspected and Alleged FCPA Violations: An Overview On Compliance Hotlines and Other Selected Topics," American Conference Institute FCPA Boot Camp 2008, January 24-25, 2008
  • Civic involvement

    Cristina has donated many hours of her time to helping others via the Houston Volunteer Young Lawyers Program. Since 2006, she has helped several dozen clients and has totaled more than 360 pro bono hours. The following are other examples of her service to the community:

    • Junior Achievement, volunteer (2007 - 2009)
    • Young Women's Leadership Conference, organizer for Fulbright & Jaworski L.L.P. in partnership with PricewaterhouseCoopers (2008)
  • Licenses
    • Texas State Bar License