Chris Brewster’s wide-ranging practice before Congress and government agencies draws on his experience as legislative and committee counsel in the United States Senate, as a state assistant attorney general, as a senior official with the Federal Trade Commission (FTC) and over 30 years of private practice.
As a member of the National Security/CFIUS/Compliance Practice Group, Mr. Brewster represents foreign and domestic clients in acquisitions that affect U.S. national security; helps foreign-owned clients acquire and maintain security clearances; and advises on compliance with U.S. trade sanctions and embargoes, U.S. export control laws, the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws.
He has represented clients in suspension and debarment proceedings before the Department of Defense, the Air Force, the Army, the U.S. Department of State, and the Environmental Protection Agency, and in export compliance matters before the U.S. Department of State, the U.S. Department of Commerce and the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), including licensing proceedings, voluntary disclosures and the defense of government investigations and enforcement actions. His FCPA experience includes an internal investigation involving the United Nations Oil for Food program, defense of an SEC investigation involving bribery allegations in Eastern Europe, and the development of numerous corporate compliance policies and anti-bribery training programs.
Mr. Brewster directs Stroock’s legislative practice, offering analysis as well as advocacy on matters before Congress and regulatory agencies.
He has advised clients on numerous legislative and regulatory matters, including representation before Congress on labor and employment, antitrust, tax, federal contracting and telecommunications legislation, and in drafting comments in federal regulatory proceedings. He has supported the defense of a Congressional investigation, developed federal and national lobbying campaigns, and advised on compliance with federal election, lobbying and ethics laws. A former radio and television broadcaster, he has also helped structure media campaigns and communications strategies.
Mr. Brewster also counsels and represents clients on consumer product safety, advertising and other consumer protection matters before state and federal agencies, including the FTC and the U.S. Consumer Product Safety Commission (CPSC). He counsels clients on compliance with the Consumer Product Safety Act, the Consumer Product Safety Improvements Act and related statutes and regulations. He has counseled clients in product recalls and in a civil penalty proceeding before the CPSC, and has developed compliance programs, crisis management policies and public service campaigns.
He also advises clients on advertising and marketing issues, including false advertising, warranties, testimonials, and new media campaigns, and has represented clients in enforcement matters and rulemakings before state attorneys general and the FTC. He has also helped develop numerous national and regional sweepstakes, contests and promotions.
Before joining Stroock, Mr. Brewster was counsel in a major international law firm. Before private practice, he was Associate Director for Marketing Practices in the FTC’s Bureau of Consumer Protection, with principal responsibility for prosecution of consumer fraud warranties and defective products, among other matters.
Prior to joining the FTC, Mr. Brewster was a legislative assistant and committee counsel for U.S. Senator John C. Danforth (R-MO) and counsel to the U.S. Senate Committee on Governmental Affairs (now the Committee on Homeland Security and Governmental Affairs). He helped draft numerous federal laws, including the Ethics in Government Act and the Paperwork Reduction Act, which created the White House Office of Information and Regulatory Affairs.
Mr. Brewster also served as a state assistant attorney general in Missouri, where he prosecuted consumer fraud cases and criminal appeals, and represented the state labor board.
- Over 100 Exon-Florio reviews before CFIUS on acquisitions ranging in value from less than $1 million to $38 billion, including: representation of a German multi-national before CFIUS and the Directorate of Defense Trade Controls in connection with a $5 billion acquisition by a Chinese corporation, the largest acquisition ever of a German company by a Chinese buyer; acquisitions by one of the principal industrial groups operating worldwide in the aerospace, defense and security sectors, by the world’s largest supplier of commercial airplane assemblies and components; negotiation and implementation of CFIUS National Security Agreements to resolve investigations and clear transactions.
- FCPA investigations, training and compliance programs.
- Mitigation of Foreign Ownership Control or Influence (FOCI) for foreign-owned, cleared U.S. government contractors. Obtained only Secretarial waivers ever granted of statutory prohibition against contracting with foreign government-controlled corporations on highly classified defense projects, drafted and helped secure amendments to federal law allowing similar waivers for environmental remediation contracts.
- Export-control matters before the U.S. Departments of State and Commerce.
- Trade sanctions matters before the U.S. Department of the Treasury, OFAC and OFAC Compliance Programs.
- Successful resolution of debarment and suspension actions in negotiated agreements, allowing contractors to return to work on government projects.
- Defense of enforcement actions by FTC and CPSC.
- Advice and counsel on product recalls of toys, consumer electronics, furniture, clothing, construction materials and electrical components.
Honors & Awards
Mr. Brewster has been recognized by Chambers USA: America’s Leading Lawyers for Business, which cites his experience in matters before CFIUS. He has also been identified by Chambers as a “Leading Individual for International Trade: Export Controls & Economic Sanctions.”
Speeches & Events
Mr. Brewster has lectured throughout the United States on FCPA compliance, as well as on legislative and regulatory issues. Select engagements include:
- Speaker, “CFIUS in a Time of Change: How Investors and Counsel Must Adapt to a Changing Environment for Foreign Investment Reviews,” PLI Webcast, June 14, 2018
- Speaker, “The Annual Aerospace & Defense Acquisitions Roundtable,” Washington, DC, April 19, 2016
- Speaker, “CFIUS Annual Report: 147 Reviews. 24 Chinese.,” PLI Webinar, April 7, 2016
- Speaker, Special Briefing for Embassy of the United Kingdom, Washington, DC, February 26, 2016
- Speaker, U.S. Legal Implications of Foreign Direct Investment, Briefing for Chinese CEO’s, Washington, DC, September 23, 2015
- Speaker, CFIUS’s Web: From Pig Farms to the Waldorf – How Real Estate and Other Transactions Outside the Defense Sector May Trigger CFIUS Review, PLI Webcast, February 5, 2015
- Speaker, Ralls Corporation v. Committee on Foreign Investment in the United States: Is This Landmark Ruling the Dawn of Due Process for CFIUS? PLI Webinar, September 18, 2014
- Speaker, “Legal and Regulatory Issues that Make the Defense Sector Unique,” The Defense Industry in a Time of Change, New York City Bar Association, March 27, 2014
- Speaker, “Government Security: FOCI and Other Key Issues,” Annual Meeting of the Aerospace General Counsel’s Group, Charleston, SC, November 4, 2010
- Speaker, “Green Labeling and Deceptive Labeling Practices,” Consumer Specialty Products Association’s Consumer Product Labeling Workshop, Chicago, IL, October 16, 2008
- Speaker, “Federal Trade Commission Green Guides,” Joint Committee Annual Meeting, Textile Rental Services Association, Salt Lake City, UT, August 4, 2008
Select publications include:
- Co-author, “Outside Director/Proxy Holder Requirements Are Changing” Stroock Special Bulletin, October 15, 2019
- Co-author, “Real Estate Transactions Impacted by New CFIUS Regulations,” Stroock Special Bulletin, September 23, 2019
- Co-author, “CFIUS Reform Flies, But With Clipped Wings,” Stroock Special Bulletin, July 26, 2018
- Co-author, “CFIUS Reform Easily Passes Senate,” Stroock Special Bulletin, June 19, 2018
- Co-author, “Under close inspection,” Intellectual Property Magazine, February 28, 2018
- Co-author, “Second Helpings: New Legislation Would Give Agriculture and HHS Secretaries Seats at the CFIUS Table,” Stroock Special Bulletin, March 21, 2017
- Co-author, “NISPOM Amendments Affect All Cleared Contractors,” Pratts Government Contracting Law Report, September 2016
- Co-author, “Food for Thought: SAFE Act Would Add the USDA to CFIUS,” Stroock Special Bulletin, August 11, 2016
- Co-author, “CFIUS Reviews are a Reality for More and More Cross-Border Transactions,” California International Law Journal, Summer 2016
- Co-author, “NISPOM Amendments Affect All Cleared Contractors,” Stroock Special Bulletin, May 25, 2016
- Co-author, “China On Top: China Dominates CFIUS Reviews for Third Year in a Row,” Stroock Special Bulletin, February 19, 2016
- Co-author, “Good News For Foreign Investors In US Defense Industry,” Aerospace & Defense and Government Contracts Law360, January 27, 2016
- Co-author, “What Real Estate Cos. Need To Know About CFIUS Reviews,” Law360, January 5, 2016
- Co-author, “CFIUS and The Waldorf Astoria,” Stroock Special Bulletin, December 21, 2015
- Co-author, “FOCI Mitigation Update: DSS Moves to a Risk-Based Approach and the NID Process Sees Incremental Improvement,” Stroock Special Bulletin, November 23, 2015
- Co-author, “Why Compliance Matters,” Stroock Special Bulletin, November 19, 2015
- Co-author, “Will Loosening Cuban Trade Sanctions be a Boon for U.S. Business? Not Necessarily,” Stroock Special Bulletin, October 15, 2015
- “U.S. Defense Department Says Climate Change Threatens National Security – So How Green is Your Deal?” Financier Worldwide, January 2015
- Co-author, “The Elephant in the Room,” Stroock Special Bulletin, December 4, 2017
- Co-author, “Four Things You Need to Know About the CFIUS Reform Legislation,” Stroock Special Bulletin, November 8, 2017
- Co-author, “Some Secret and Not-So-Secret Findings in the CFIUS Annual Report,” Stroock Special Bulletin, September 29, 2017
- Co-author, “New Reporting Requirements For Foreign Travel and Foreign Contacts by Government Contractors,” Stroock Special Bulletin, July 17, 2017
Admitted To Practice
District of Columbia; Missouri
Harvard University, John F. Kennedy School of Government, Graduate Program for Senior Managers in Government, 1982
J.D., University of Virginia School of Law, 1975
A.B., cum laude, with High Honors in Government, Dartmouth College, 1972
In The Spotlight
PublicationsBack To Full Bio
April 2, 2020 | Stroock Special Bulletin
An Old Law for the New War: Defense Production Act Not Just for Government Contractors
March 31, 2020 | Stroock Special Bulletin
Mapping Risk: New CFIUS Tool for Real Estate Investors
March 26, 2020 | Stroock Special Bulletin
COVID-19, CFIUS and the Defense Production Act
March 5, 2020 | Stroock Special Bulletin
CFIUS Filing Fees: Proposed Rule Announced
January 22, 2020 | Stroock Special Bulletin
New Decade, New CFIUS: New Rules Expand CFIUS Reach Into Non-controlling Investment and Real Estate
January 13, 2020 | Stroock Special Bulletin
Breaking News: Final CFIUS Regulations Published by Treasury
January 6, 2020 | Stroock Special Bulletin
CFIUS and Foreign Investment: 2020 Brings Changes to U.S. National Security Regulations
October 15, 2019 | Stroock Special Bulletin
Outside Director/Proxy Holder Requirements Are Changing
September 23, 2019 | Stroock Special Bulletin
Real Estate Transactions Impacted by New CFIUS Regulations
July 26, 2018 | Stroock Special Bulletin
“CFIUS Reform Flies, But With Clipped Wings”
June 19, 2018 | Stroock Special Bulletin
“CFIUS Reform Easily Passes Senate”
November 8, 2017 | Stroock Special Bulletin
“Four Things You Need to Know About the CFIUS Reform Legislation”
September 29, 2017 | Stroock Special Bulletin
"Some Secret and Not-So-Secret Findings in the CFIUS Annual Report"
July 17, 2017 | Stroock Special Bulletin
"New Reporting Requirements For Foreign Travel and Foreign Contacts by Government Contractors"
March 21, 2017 | Stroock Special Bulletin
"Second Helpings: New Legislation Would Give Agriculture and HHS Secretaries Seats at the CFIUS Table"
August 11, 2016 | Stroock Special Bulletin
"Food for Thought: SAFE Act Would Add the USDA to CFIUS"
May 25, 2016 | Stroock Special Bulletin
"NISPOM Amendments Affect All Cleared Contractors"
February 19, 2016
China On Top: China Dominates CFIUS Reviews for Third Year in a Row
12/21/15 | Stroock Special Bulletin
"CFIUS and The Waldorf Astoria"
November 23, 2015 | Stroock Special Bulletin
"FOCI Mitigation Update: DSS Moves to a Risk-Based Approach and the NID Process Sees Incremental Improvement"
November 19, 2015 | Stroock Special Bulletin
"Why Compliance Matters"
October 15, 2015
"Will Loosening Cuban Trade Sanctions be a Boon for U.S. Business? Not Necessarily"