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Cristina K. Lunders

Senior Counsel

Cristina K. Lunders


T:+1 713 651 5619

Cristina Lunders joined Norton Rose Fulbright's Houston office in 2006 and has significant experience in assisting clients with diverse regulatory 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, 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 drilling companies in conducting due diligence into joint venture partners, commercial agents, and logistics providers.
    • 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.
  • Admissions
    • Texas State Bar
  • Publications
    • Co-author, "Avoid Noncompliance in International Human Rights Obligations," Texas Lawyer, March 1, 2016 
    • Co-author, "DC Circuit confirms conflict minerals ruling," Norton Rose Fulbright - Legal update, August 20, 2015
    • Co-author, "FCPA and the construction industry - Settlement highlights risks for construction companies," Norton Rose Fulbright - Legal update, July 2015
    • Co-author, "SEC award for whistleblowing compliance officer - At least $1.4M awarded under substantial injury exception," Norton Rose Fulbright - Legal update, April 29, 2015
    • Co-author, "Corporate officer receives whistleblower award," Norton Rose Fulbright - Legal update, March 6, 2015
    • Co-author, "The Dodd-Frank Act whistleblower provisions and the SEC whistleblower program in 2014," State Bar of Texas: Corporate Counsel Section Newsletter, Winter 2015
    • Co-author, "Facilitating payments: Guidance on criticized FCPA exception," Norton Rose Fulbright - Legal update, February 2015
    • Co-author, "FCPA and shareholder lawsuits: Avon wins dismissal, but companies must remain vigilant," Norton Rose Fulbright - Legal update, October 2014
    • Co-author, "SEC awards compliance employee whistleblower $300K," Norton Rose Fulbright - Legal update, September 2014
    • Co-author, "SEC awards $30 million to foreign whistleblower," Norton Rose Fulbright - Legal update, September 2014
    • Co-author, "SEC issues new Conflict Minerals Guidance post NAM," Norton Rose Fulbright - Legal update, May 8, 2014
    • Co-author, "DC Circuit vacates part of Conflict Minerals rule," Norton Rose Fulbright - Legal update, April 22, 2014
    • Co-author, "SEC issues new guidance on conflict minerals rule," Norton Rose Fulbright - Legal update, April 11, 2014
    • Co-author, "Cutting the ties that bind - Company obtains favorable FCPA Opinion for government official buyout," Norton Rose Fulbright - Legal update, March 27, 2014
    • Co-author, "Stryker pays $13.2 million to SEC to resolve FCPA allegations," Norton Rose Fulbright - Legal update, October 28, 2013
    • Co-author, "U.S. and EU Disclosure Requirements For the Extractive Industries," Fulbright Briefing, May 16, 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 Briefing, April 25, 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, "DOJ and SEC Settlements With Daimler Highlight Increased Fine and Imposition of Monitor for FCPA Violators," Fulbright Alert, April 2, 2010
    • Co-author, "DOJ Launches the Largest Single Investigation and Prosecution Action Against Individuals in the History of the FCPA," Fulbright Alert, January 20, 2010
    • Co-author, "Increased International Anti-Corruption Enforcement Highlighted in Fine Imposed by German Authorities," Fulbright Briefing, December 18, 2009
    • Co-author, "Individual Enforcement and International Cooperation Highlighted in FCPA Guilty Plea," Fulbright Briefing, September 8, 2009
  • Speaking engagements
    • Moderator, "The Panama Papers," Houston Bar Association, International Law Section, May 11, 2016
    • Speaker, "FCPA and International Anti-Corruption," International Law Career Panel, South Texas College of Law, Houston, Texas, April 6, 2016
    • Speaker, "The U.S. Foreign Corrupt Practices Act," Houston Corporate Paralegal Association CLE Luncheon, Houston, Texas, July 8, 2015
    • Speaker, "Enforcement and Trial of a Foreign Corrupt Practices Act (FCPA) Case," State Bar of Texas, International Law Section 2015 "Nuts & Bolts" of International Law, Houston, Texas, May 29, 2015
    • Speaker, "M&A in 2015:  Successor Liability Under the FCPA," Norton Rose Fulbright Web seminar, Houston, Texas, February 26, 2015
    • Speaker, "Compliance Risk Assessments," Houston Bar Association, November 12, 2014
    • Speaker, "M&A and the Foreign Corrupt Practices Act," Norton Rose Fulbright M&A School, October 22, 2014
    • Speaker, "Practicing Ethically in Rule of Law Challenged Countries," National Association of Legal Secretaries, October 3, 2014
    • Speaker, "Introduction to Accounting and Financial Statements," Deloitte, September 30, 2014
    • 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
  • Memberships and activities
    • Chair, Houston Young Lawyers Foundation 2017/2018
    • Chair, Houston Bar Association International Law Section 2017/2018
    • Council Member, State Bar of Texas International Law Section 2017/2018
    • Chair-Elect, Houston Young Lawyers Foundation 2016/2017
    • Vice Chair, Houston Bar Association International Law Section 2016/2017
    • Council Member, State Bar of Texas International Law Section 2016/2017
    • Founding Member, State Bar of Texas International Law Section Committee on Human Rights, 2015/Present
    • Secretary, Houston Bar Association International Law Section 2015/2016
    • Trustee, Houston Young Lawyers Foundation Board of Trustees 2015/2016
    • Council Member, Houston Bar Association International Law Section 2014/2015
    • Secretary, Houston Young Lawyers Foundation Board of Trustees 2014/2015
    • Fellow, Houston Young Lawyers Foundation
    • Houston Bar Association Speaker's Bureau 2015/2016

    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)