As Co-Chair of the firm's White-Collar Defense & Investigations practice, Deborah Curtis draws on her distinguished career as a supervisory federal prosecutor, regulatory chief counsel, and senior intelligence officer at CIA, to defend clients across all sectors who may be facing U.S. government investigation, regulatory scrutiny, or criminal charges. She also advises clients on how to navigate highly-sensitive national security issues.
As a prosecutor, Deborah first-chaired 47 trials and supervised hundreds of federal criminal investigations. Her considerable experience spans two major U.S. Attorney's Offices and a leadership position in DOJ's Counterintelligence and Export Control Section.
Her expertise includes:
- Transnational criminal matters relating to sanctions and export control violations; narcotics trafficking; immigration offenses; international terrorism; and other cross-border investigations.
- U.S. government national security policy decisions (e.g., Entity List) and enforcement actions before the U.S. Department of Commerce, U.S. Department of State, U.S. Department of Defense, and U.S. Department of Justice.
- Espionage, Illegal Foreign Agents, Foreign Agents Registration Act (FARA), and other criminal and civil matters involving classified national security information, including the Classified Information Procedures Act (CIPA) and state secrets privilege.
- Strategic engagement with the U.S. Intelligence Community.
Deborah also served as Chief Counsel for Industry and Security at the U.S. Commerce Department (BIS). While there, Deborah co-drafted the seminal semiconductor “Foreign Direct Product Rule,” advised the Committee on Foreign Investment in the United States (CFIUS), and co-wrote the U.S. Information and Communications Technology and Services (ICTS) supply chain regulation.
Immediately prior to joining Arnold & Porter, Deborah served as a Deputy General Counsel for the Central Intelligence Agency, overseeing all litigation and investigations facing CIA, including congressional inquests, criminal charges, security breaches, and the invocation of state secrets and diplomatic privileges and immunities.
Deborah also served at the Pentagon advising on national security matters implicating Cleared Defense Contractors and Special Access Programs, and as an active duty JAG officer at the U.S. Air Force Academy, attaining the grade of Major.
Experience
- Global provider of critical digital infrastructure solutions. Obtained warning letter after voluntary self-disclosure for export control violations.
- Military avionics company. Won declination of criminal charges and administrative warning letter after allegations of willful export control violations.
- Binance. Secured release of an employee of the world's largest cryptocurrency exchange from Nigerian government custody.
- Former U.S. intelligence officer. Defended against Espionage Act charges.
- Multiple major semiconductor manufacturers in engaging the U.S. Departments of Commerce, Defense, and State.
- Independent Counsel for the District of Columbia appointed to conduct review of high-profile sexual harassment investigation, evaluate broader claims of sex-related workplace malfeasance, and recommend policy changes.
- Leading global critical digital infrastructure provider in evaluating possible violations of Commerce Department’s Huawei foreign direct product rule.
- Military avionics company in navigating criminal and administrative investigations into possible export control violations.
- Government Senior Executive in confidential reporting of sex discrimination and potential classified information security violations.
- At DOJ, supervised the investigation and prosecution of a subsidiary of the world’s largest oilfield services company for violating U.S. sanctions against Iran and Sudan and resulted in $230 million financial penalty.*
- At DOJ, prosecuted former member of White House National Space Council for espionage for providing classified information to a person he believed to be an Israeli intelligence officer.
- At DOJ, supervised the prosecution of UniCredit Bank AG (UCB AG), for violations of U.S. sanctions, resulting in $1.3 billion financial penalty.*
- At DOJ, prosecuted Academi LLC, formerly known as Blackwater Worldwide and Xe Services LLC, resulting in a $7.5 million criminal fine and $42 million settlement for violations of U.S. export control laws, after a five-year, multi-agency federal investigation.*
- At DOJ, supervised the prosecution of Russian national who pled guilty to conspiracy to act in the U.S. as an unregistered agent of Russia.*
*Matter completed prior to joining the firm.
Perspectives
Recognition
Credentials
Education
- J.D., Georgetown University Law Center, 1994, cum laude, Alan J. Goldstein Memorial Award
- B.S., University of Southern California, 1991, cum laude, Beta Gamma Sigma National Honor Society, Dean's List
Admissions
- District of Columbia
- California
Government & Military Service
- Deputy General Counsel for Litigation and Investigations, Central Intelligence Agency (2020-2023)
- Chief Counsel for Industry and Security, U.S. Department of Commerce (2019-2020)
- Deputy Chief for National Security; Assistant U.S. Attorney, U.S. Department of Justice (2015-2019)
- Deputy Chief for Export Control and Sanctions and Trial Attorney, Counterespionage Section, U.S. Department of Justice (2007-2015)
- Associate Deputy General Counsel, U.S. Department of the Air Force (2005-2007)
- Judge Advocate, U.S. Department of the Air Force (1997-2005)
- Assistant U.S. Attorney (adjunct), U.S. Department of Justice (1995-1997)
Activities
- Member, Law360’s 2025 Aerospace & Defense Editorial Advisory Board
- Adjunct Professor, Strategic Intelligence & Public Policy, Georgetown Law (2024-present)
- Leadership Council Member, Leadership Council for Women in National Security (2024-present)
- Senior Lecturer (Public Policy), University of Virginia, "National Security in the Age of New Technology"