O’Melveny Worldwide

David J. Ribner’s practice focuses on counseling US and non-US clients on international trade and investment regulatory matters, including trade and anticorruption compliance. His clients span a variety of industries, with a focus on companies operating in the technology and energy sectors.

David has extensive experience securing national security clearance by the Committee on Foreign Investment in the United States (CFIUS), having served as CFIUS counsel in transactions with investors spanning the globe and myriad industries.

David also counsels clients on compliance with US economic sanctions, export controls, customs laws, and antiboycott regulations, as well as the Foreign Corrupt Practices Act (FCPA), and advises on the development and implementation of related corporate compliance programs. When potential violations of such laws arise, he conducts internal investigations and assists with 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 the Nuclear Regulatory Commission.

David is consistently recognized by Chambers USA with a ranking as a CFIUS expert and by Chambers Global as an “Up-and-Coming” CFIUS expert. He has also been recommended as a Rising Star for International Trade: CFIUS by The Legal 500 US and named to Global Competition Review, Foreign Investment Control’s “40 Under 40,” which recognizes the world’s top foreign investment lawyers under age 40. David frequently speaks and publishes on topics related to international trade.

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Representative CFIUS Experience

  • IBM in connection with multiple transactions, including the sale of its x86 server business to Lenovo, the sale of its global semiconductor manufacturing business to GLOBALFOUNDRIES, and the sale of select IBM software products to HCL Technologies
  • Mitsui & Co. in connection with its acquisition of Spaceflight, Inc., a space launch rideshare company, and its investment in Airspan Networks Inc., a communications equipment company
  • A European multinational company in connection with CFIUS matters involving multiple acquisitions of US physical and logical access control and security equipment businesses
  • DigitalGlobe, Inc. in its acquisition by Macdonald, Dettweiler and Associates Ltd.
  • OMERS Infrastructure, the infrastructure investment manager of the Ontario Municipal Employees Retirement System, in the US$800 million sale of portfolio company Airports Worldwide to Vinci Airports, a subsidiary of Vinci Group
  • Mentor Graphics Corporation in its US$4.5 billion acquisition by Siemens Industry, Inc., a leader in global technology, focusing on the areas of electrification, automation, and digitalization
  • Analogix Semiconductor in its acquisition by Beijing Shanhai Capital Management Co, Ltd.
  • A buyer consortium led by Yunfeng Capital, TF Capital and Tony (Bizuo) Liu, in a going private transaction involving Cellular Biomedicine Group, Inc. (Nasdaq: CBMG).

Representative Economic Sanctions & Export Control Experience

  • Conducted internal investigations relating to potential violations of economic sanction laws, antiboycott laws and, the Export Administration Regulations (EAR)
  • Represented U.S. and non-U.S. companies in 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 SEC, the Commerce Department’s Office of Export Enforcement, the State Department, and OFAC, and in settling pending enforcement matters before such agencies
  • Conducted assessments and audits of economic sanctions and export control compliance programs in a variety of industries
  • Advised on the development and implementation of corporate compliance programs in the areas of export controls, economic sanctions, customs, and the antiboycott laws
  • Represented US and non-US companies in obtaining a range of authorizations, licenses and advisory opinions under the EAR, the ITAR, as well as the economic sanctions regulations governing trade with Cuba, Iran, Iraq, Sudan, and Syria
  • Advised on the consequences of changes in economic sanctions laws, including Russia/Ukraine, Iran and Cuba sanctions programs

Representative FCPA Experience

  • In response to FCPA inquiries from the U.S. government, conducted an investigation for a leading tech company of the company’s operations in numerous countries across Asia, Africa, and South America
  • Represented former corporate executive of Brazilian company in connection with DOJ investigation into FCPA violations regarding alleged bribes to state-owned enterprise
  • Represented former corporate executives of Brazilian company in connection with DOJ investigation regarding alleged payments to political officials

Admissions

Bar Admissions

  • District of Columbia
  • New York

Education

  • Georgetown University, J.D.
  • King's College London, University of London M.A.
  • Columbia University, B.A.

Honors & Awards

  • Recommended by Who's Who Legal for Foreign Investment Control (2024)
  • Named to the "40 Under 40" list by Global Competition Review, Foreign Investment Control (2023)
  • Ranked as a Rising Star by The Legal 500 US for International Trade: CFIUS (2023)
  • Named to the Washington, DC Rising Stars list by Super Lawyers (2016-2019, 2023)
  • Named "Up & Coming" by Chambers USA for International Trade: CFIUS Experts (2021-2023); Chambers Global for International Trade: CFIUS Experts (2022-2023)
  • Recommended by The Legal 500 US for International Trade (2020-2022)

Professional Activities

Publications

Speaker

  • Panelist, "Hot Compliance Issues-Russia Sanctions," State Bar of Texas, 21st Annual Course-Advanced In-House Counsel (August 2022)
  • Presenter, “U.S.-China Venture Capital: Trends and Regulatory Challenges,” AmCham Shanghai (January 2020)
  • Presenter, “CFIUS for Startups and Investors,” Silicon Catalyst Angels (December 2019)
  • Panelist, “Everything Old is New Again: CFIUS and FIRRMA – How Will the Potential Changes Affect FDI in Your Company?” 97th Annual AAEI Conference and Expo (June 2018)

Client Alerts (Most Recent)

  • "CFIUS Proposes to Expand Scope of U.S. Real Estate Subject to Review" (O'Melveny National Security Alert, May 2023) (with Greta Lichtenbaum, Shruti Kannan)
  • "Unparalleled $300 Million Civil Penalty for Export Control Violations Underscores the Imperative of Strong Compliance for Companies Operating Internationally" (O'Melveny National Security Alert, April 2023) (with Sid Mody, Greta Lichtenbaum)
  • "Bipartisan Legislation Seeks to Address National Security Threats From Foreign Information and Communications Technology" (O'Melveny National Security Alert, March 2023) (with Greta Lichtenbaum, John Dermody, Shruti Kannan)
  • "CFIUS Determines that New Zealand and the United Kingdom Meet Requirements for Key CFIUS Exemptions" (O'Melveny National Security Alert, February 2023) (with Greta Lichtenbaum, Damilola G. Arowolaju)
  • “FCC Bans New Licenses for the Import and Use of Certain Chinese Telecommunications and Video Surveillance Equipment” (O’Melveny National Security Alert, December 2022) (with Greta Lichtenbaum, Sid Mody, John Dermody)
  • "CFIUS Issues Enforcement and Penalty Guidelines" (O’Melveny & Myers International Trade Alert, October 2022) (with Greta Lichtenbaum, Damilola G. Arowolaju)
  • "United States Imposes New Restrictions on Exports of Advanced Computing Chips and Semiconductor Manufacturing Items to China" (O’Melveny & Myers International Trade Alert, October 2022) (with Greta Lichtenbaum, John Dermody, Youjin Kwon)
  • "United States Expands Sanctions Targeting Russia in Response to Russia’s Purported Annexation of Regions of Ukraine" (O’Melveny & Myers International Trade Alert, October 2022) (with Greta Lichtenbaum, Youjin Kwon)
  • "Biden Administration Issues Policy Directive on National Security Reviews of Foreign Investments in U.S. Businesses" (O’Melveny & Myers  International Trade Alert, September 2022) (with Greta Lichtenbaum, Damilola G. Arowolaju)
  • "U.S. Economic Sanctions and Export Controls on Russia and Belarus Expand, with Further Measures Likely" (O’Melveny & Myers International Trade Alert, September 2022) (with Greta Lichtenbaum)
  • "Biden Administration Further Expands Sanctions on Russia as War in Ukraine Continues" (O’Melveny & Myers International Trade Alert, May 2022) (with Greta Lichtenbaum, Damilola G. Arowolaju)