Greta Lichtenbaum

Partner

Greta Lichtenbaum is a partner in O'Melveny's Washington, DC office and a member of the White Collar Defense and Corporate Investigations Practice.  Her practice principally relates to regulations governing international business transactions and trade.  Greta represents and advises clients in matters related to US economic sanctions, export controls, antiboycott, foreign investment (CFIUS), the Foreign Corrupt Practices Act ("FCPA"), anti-money laundering, customs, and trade laws and agreements.  In addition to advising clients on the application of these laws to on-going business and potential acquisitions, Greta assists clients to develop corporate compliance programs, conducts internal investigations relating to potential violations of these laws and represents companies before the relevant agencies in connection with license requests and enforcement proceedings.  She represents clients before the Treasury Department's Office of Foreign Assets Control on economic sanctions matters and the Departments of Commerce and State on export control matters.  She also represents clients before the US Bureau of Customs and Border Protection, the International Trade Commission, and the Court of International Trade in antidumping investigations and procedures, as well as in connection with other matters implicating US trade laws.

Greta is one of only 11 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 well-recognized export controls expert."  In Chambers' world-wide publication, Chambers Global 2010 and 2011, Greta ranked again in the top tier (Band 1) for the Export Controls category, and she received additional recognition in the International Trade: FCPA Experts category.

Illustrative Professional Experience

• Conducted assessment of major broker-dealer’s anti-money laundering and economic sanctions programs
• Advised investment bank on U.S. anti-money laundering risks in proposed equity investment
• Represented US and foreign companies in obtaining licenses under the Export Administration Regulations (“EAR”), as well as the economic sanctions regulations governing trade with Cuba, Iran, Iraq, and Libya
• Represented US companies in obtaining  licenses and authorizations to enter into Technical Assistance Agreements under the International Traffic in Arms Regulations (“ITAR”)
• Advised numerous companies on the development and implementation of corporate compliance programs in the areas of the Foreign Corrupt Practices Act ("FCPA"), export controls, economic sanctions, customs and the antiboycott laws
• Assisted both buyers and sellers with trade controls due diligence within the context of mergers and acquisitions
• Conducted internal investigations and audits relating to potential violations of economic sanctions laws, antiboycott laws, the FCPA, the EAR and the ITAR
• Advised various companies on the application of antiboycott laws to individual transaction and assisted on compliance with reporting requirements
• Represented numerous US and foreign companies in connection with enforcement matters arising from potential violations of economic sanctions, export control and customs laws
• 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
• Advised US companies on NAFTA rule-of-origin certification requirements
• Represented US companies in connection with “focused assessment” audits conducted by the US Bureau of Customs and Border Protection
• Represented various importers in connection with “Section 201” steel investigation
• Represented major US oil company in antidumping proceeding involving crude oil
• Represented major US computer systems manufacturers in antidumping proceedings involving various imported components
• Advised US companies on the implications of the WTO Telecommunications Agreement

Professional Activities

Member, American Bar Association, International Section; Strafford Publications' International Law Advisory Board
Author, "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)
Co-Author, “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); “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)
Speaker, "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); "Compliance Risks to Multinational Companies Arising from US Laws that Regulate International Business: Enforcement of the US FCPA and US Economic Sanctions Laws," London Stock Exchange, London (February 2009); C5 Group and American Conference Institute's International Forum on Economic Sanctions, London (February 2009); “Foreign Asset Control Compliance in Domestic and International Transactions,” Strafford Teleconference (February 2009); "OFAC Enforcement & Compliance," 2nd National Forum, Washington DC (April 2009); “What's Next? Obama's Enforcement Agenda and China,” O'Melveny and CITIC Securities, Beijing (June 2009); "Assuring Foreign Asset Control Compliance in Domestic and International Transactions," Strafford Publications Teleconference (February 2008); "Minimizing Your Risk of OFAC Violations," American Conference Institute's 6th National Forum on Conducting, Managing and Responding to Corporate Investigations, Washington DC (May 2008); "FCPA Overview: Insights Into Heightened SEC, DOJ Enforcement," Strafford Publications FCPA Teleconference (June 2008); OFAC Enforcement and Compliance American Conference Institute's Inaugural National Forum, Washington, DC (June 2008); The Re-Regulation of America After the Financial Meltdown: The View of Washington DC Insiders, Hong Kong (October 2008); “Foreign Corrupt Practices Act: Practical Corporate Compliance Solutions,” IQPC's Foreign Corrupt Practices Act Conference, Arlington, VA (September 2006) 
Honors, Recognized by BTI as a “Client Service All-Star” (2013); Recognized in The Guide to the World’s Leading Women in Business Law (2012); recognized as a leading practitioner in the Guide to the World's Leading International Trade Lawyers (2010); given top recognition from Chambers USA and Chambers Global in International Trade: Export Controls & Economic Sanctions category (2010 and 2011); given recognition from Chambers USA and Chambers Global in International Trade: FCPA Experts category (2010 and 2011); named a “Super Lawyer” in Super Lawyers - Corporate Counsel Edition (2010 and 2011); recognized in The Guide to the World’s Leading International Trade Lawyers (2010 and 2012)