is a partner in O’Melveny’s Washington, D.C. office and a member of the White Collar Defense and Corporate Investigations Practice. Her practice principally relates to compliance with U.S. laws that govern international business transactions and trade. Greta represents and advises clients in matters related to U.S. economic sanctions, export controls, anti-corruption (the Foreign Corrupt Practices Act, or “FCPA”), antiboycott, foreign investment, anti-money laundering, and customs laws. In addition to advising clients on the application of these laws to on-going business and potential acquisitions, Greta assists clients in all aspects of managing compliance with these laws, including developing corporate compliance programs, conducting internal investigations relating to potential violations of these laws and representing companies before the relevant agencies in connection with enforcement proceedings, license requests, and government inquiries. These agencies include the Treasury Department’s Office of Foreign Assets Control, the Securities and Exchange Commission, the Departments of Justice, Commerce and State, and the U.S. Bureau of Customs and Border Protection.
Greta is one of only 12 lawyers to receive top-tier (Band 1) recognition from law firm rankings publication Chambers USA
in its International Trade: Export Controls & Economic Sanctions category; Chambers
describes her as a “fantastic lawyer” and “well-recognized export controls expert.” In Chambers’ world-wide publication, Chambers Global
, Greta ranked again in the top tier (Band 1) for the Export Controls category and received additional recognition in the FCPA Experts category.
Illustrative Professional Experience
Compliance Risk Assessments and Audits
- Conducts assessments and audits of compliance programs in a variety of industries, such as a multi-national semiconductor manufacturer’s export control compliance program, a provider of nutritional supplements’ FCPA compliance program, an oilfield service company’s antiboycott program, and a major broker-dealer’s anti-money laundering and economic sanctions programs.
Licensing, Classifications, and Advisory Opinions
- Represents U.S. and foreign companies in obtaining a range of authorizations, licenses and advisory opinions under the Export Administration Regulations (“EAR”), the International Traffic in Arms Regulations (“ ITAR”), as well as the economic sanctions regulations governing trade with Cuba, Iran, Iraq, and Libya. Examples include licenses authorizing activities associated with terminating operations in Iran, Technical Assistance Agreements, export control authorizations for encryption and oilfield service products, OFAC licenses for reinsurance activity, commodity classification ruling requests, and commodity jurisdiction filings.
Development of Compliance Programs and Procedures
- Advises companies in a wide range of sectors on the development and implementation of corporate compliance programs in the areas of FCPA, export controls, economic sanctions, customs, and the antiboycott laws.
- Advises companies in various sectors (including semiconductor, oilfield services, energy exploration, hospitality, insurance and reinsurance, and a range of other financial services) on legal issues arising under trade controls, antibribery, antiboycott, customs, and anti-money laundering laws. Examples include having advised an investment bank on U.S. anti-money laundering risks in a proposed equity investment; advised U.S. companies on NAFTA rule-of-origin certification requirements; advised numerous clients on the consequences of changes in economic sanctions laws, including the easing of Burma sanctions and the expanded reach of U.S. economic sanctions targeting Iran; and advised semiconductor sector clients on changing legal obligations arising from Export Control Reform.
- Advises parties on FCPA and trade controls due diligence within the context of mergers and acquisitions, financings, and IPOs. Assists with due diligence, appropriate contractual protections and undertakings, as well as post-acquisition planning.
Enforcement Proceedings and Internal Investigations
- Conducts internal investigations relating to potential violations of economic sanction laws, antiboycott laws, the FCPA, the EAR, and the ITAR and Customs rules.
- Represents U.S. and foreign companies in connection with enforcement matters arising from potential violations of economic sanctions, export control, and customs laws, including assisting clients in responding to subpoenas and other information requests from the Department of Justice, the Securities and Exchange Commission, the Commerce Department’s Office of Export Enforcement, the Treasury Department’s Office of Foreign Assets Control, and in settling pending enforcement matters before such agencies.
Government Proceedings and Inquiries
- Prepared a number of voluntary notices to the Committee on Foreign Investment in the United States on behalf of both foreign investors and domestic targets.
- Represented U.S. companies in connection with “focused assessment” audits conducted by the U.S. Bureau of Customs and Border Protection.
District of ColumbiaHonors
, Recognized by BTI as a “Client Service All-Star” (2013); recognized in The Guide to the World’s Leading Women in Business Law
(2012); given top recognition from Chambers USA and Chambers Global in International Trade: Export Controls & Economic Sanctions category (2010-2013); given recognition from Chambers USA and Chambers Global in International Trade: FCPA Experts category (2010-2013); named a “Super Lawyer” in Super Lawyers - Corporate Counsel Edition
(2010-2012); recognized in The Guide to the World’s Leading International Trade Lawyers
(2010 and 2012)
“Iran Sanctions Mean Multinationals Need To Prepare for Close Scrutiny,” Corporate Counsel
(March 2012); Chapters, “Export Controls” and “FCPA/Antibribery,” Corporate Compliance Practice Guide: The Next Generation
(Matthew Bender/LexisNexis, 2009)
Foreign Corrupt Practices Act: An O’Melveny Handbook
, one of the lead authors of the Firm’s Fifth, Sixth and Seventh Editions of this well-regarded Handbook
“The Extraterritorial Scope of the FCPA as Addressed in New Government Guidance,” in Competition Policy International Antitrust Chronicle
(December 2012; co-authored with Beth France); "Economic sanctions laws: the European Union and the United States,” a chapter published in Serious Economic Crime: A Boardroom Guide to Prevention and Compliance
(Published by White Page Ltd in association with the Serious Fraud Office; December 2011) (with James Barratt and Hayley Ichilcik)
Numerous alerts on legal developments, including most recently: “SEC Staff Publishes C&D Is Regarding Disclosure Requirements for Issuers Engaged in Certain Activities in Iran,” (O’Melveny & Myers Capital Markets Alert, December 2012) (with Marty Dunn, David Lavan, and Bjorn Hall); “SEC and DOJ Release Long Awaited Joint FCPA Guidance” (O’Melveny & Myers Foreign Corrupt Practices Act Alert, November 2012) (with Richard Grime, Jeremy Maltby, Daniel Bookin, Dan Shallman, Howard E. Heiss, Melissa Jackson, and Beth France); “Broad New Legislation Further Expands Economic Sanctions Against Iran and Syria,” (O’Melveny & Myers International Trade Alert, August 2012) (with Theodore Kassinger); “U.S. Suspends Economic Sanctions Against Burma,” (O’Melveny & Myers International Trade Alert, July 2012) (with Theodore W. Kassinger and Ronak D. Desai); “New Iran and Syria Sanctions Pose Compliance Challenges for both U.S. and non-U.S. Businesses,” (O’Melveny & Myers International Trade Alert, May 2012) (with Theodore W. Kassinger and James William Barratt); “Opening Up Myanmar To EU Investment,” Law360
(May 2012) (with Theodore W. Kassinger, James Barratt, Hayley Ichilcik, and Ronak D. Desai); “Burma/Myanmar Opens for Business from the EU,” (O’Melveny & Myers International Trade Alert, April 2012) (with Theodore W. Kassinger, James William Barratt, Hayley Ichilcik, and Ronak D. Desai); “Following the U.S. Lead, the European Union Expands Its Sanctions Against Iran,” (O’Melveny & Myers International Trade Alert, January 2012) (with James William Barratt and Hayley Ichilcik)Speaker,
Recent speaking engagements include: “U.S. Economic Sanctions Enforcement & Compliance,” ACI's 6th National Summit, Washington, DC (June 2013); “The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2013,” PLI New York Center (May 2013); “WMACCA Global Issues Forum: Detecting Red Flags When Dealing with Foreign Officials,” WMACCA (February 2013); “Benefiting From Convergence: Streamlining Your AML, Fraud Prevention, OFAC, and FCPA Programs and Leveraging Existing Resources to Increase Efficiency and Reduce Costs,” American Conference Institute’s 3rd Annual Forum on AML & OFAC Compliance for the Insurance Industry (January 2013); “Women Partners: Lessons Learned on How to be a Leader and Still Have a Life,” PLI (October 2012); “New Developments in U.S. Export Controls and Economic Sanctions Law,” American Bar Association's 6th Annual Homeland Security Law Institute Conference, Washington, DC (March 2011); “Coping with U.S. Export Controls 2011,” PLI, Washington, DC (December 2011); OFAC Enforcement and Compliance, 3rd National Forum, Washington DC (Co-Chair, April 2010)