Greta Lichtenbaum

Partner

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Greta Lichtenbaum is chair of O’Melveny’s National Security Group. Greta’s practice focuses on compliance with US laws that govern international business transactions and trade. She represents and advises clients in matters related to US economic sanctions, export controls, anti-corruption (the Foreign Corrupt Practices Act, or “FCPA”), foreign investment, money laundering, antiboycott, 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, clearances, license requests, and government inquiries. These include the Treasury Department’s Office of Foreign Assets Control (OFAC), the Committee on Foreign Investment in the United States (CFIUS), the Departments of Justice, Commerce and State, the Securities and Exchanges Commission (SEC), and the US Bureau of Customs and Border Protection.

Greta is highly ranked by both Chambers USA and Chambers Global. Chambers has described her as the “dean of the sanctions bar” and notes that in the area of export controls she “combines experience with technical knowledge to provide extremely valuable counsel,” is “very knowledgeable about the arcana in this area” and “very skilled at helping the client get that end result.” Chambers also notes Greta’s “great contacts at OFAC” and “very commercial approach” as key strengths. Greta has deep experience advising clients in a range of industry sectors, including financial, insurance, Fintech, energy, semiconductor, defense, and telecommunications.

Honors & Awards

  • Named one of Global Investigation Review’s “25 Most Respected Sanctions Lawyers” in Washington, DC (2019)
  • Ranked Band 1 Nationwide by Chambers Global and Chambers USA for International Trade: Export Controls & Economic Sanctions (2009-2014; 2016-2022)
  • Recognized by Chambers Global for International Trade: CFIUS Experts (2022)
  • Named a “Super Lawyer” in International Law in Super Lawyers - Washington, DC edition (2013-2014; 2017)
  • Recognized by The Legal 500 US for having expertise in International Trade (2014-2021)
  • Recommended in Trade & Customs (2018-2019); Trade & Customs - International Sanctions (2019) by Who’s Who Legal
  • Recognized by BTI as a “Client Service All-Star” (2013)
  • Recognized in The Guide to the World’s Leading Women in Business Law (2012)
  • 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)

Admissions

Bar Admissions

  • District of Columbia

Education

  • Harvard University, J.D., 1990: Managing Editor, Harvard Human Rights Journal; Member, International Law Society
  • Haverford College, B.A., 1986: Phi Beta Kappa, Departmental Honors

Professional Activities

Publications

  • One of the lead authors of the Fifth, Sixth and Seventh Editions of the Firm’s well-regarded FCPA Handbook
  • Chapters, “Export Controls” and “FCPA/Antibribery,” Corporate Compliance Practice Guide: The Next Generation (Matthew Bender/LexisNexis, 2018)
  • “US Economic Sanctions Laws - Opportunities And Compliance Challenges,” Risk and Compliance Magazine (April 2017) (with McAllister Jimbo)
  • “Iran Nuclear Agreement: Compliance Strategies for Companies Considering Doing Business with Iran,” Corporate Counsel (January 2016) (with Hayley Ichilcik)
  • “The Extraterritorial Scope of the FCPA as Addressed in New Government Guidance,” in Competition Policy International Antitrust Chronicle (December 2012) (with Beth France)
  • “Iran Sanctions Mean Multinationals Need To Prepare for Close Scrutiny,” Corporate Counsel (March 2012)
  • “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

  • Co-chair, "Sanctions & Anti-Money Laundering 2022," Global Investigations Review (November 2022)
  • "The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2022," Practising Law Institute (April 2022)
  • “5 Months into Biden Administration: Sanctions Update and What to Expect,” American Conference Institute (June 2021)
  • “The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2021,” Practising Law Institute (April 2021)
  • “The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2020,” Practising Law Institute (September 2020)
  • Co-Chair, "13th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance," American Conference Institute (July 2020)
  • “CFIUS and the Newly Expanded Scope of Foreign Direct Investment Reviews,” Practising Law Institute (March 2020)
  • “Trump Administration Trade Policy and Impact on the Energy Industry,” The Center for American and International Law’s 71st Annual Oil & Gas Law Conference (February 2020)
  • “Coping with US Export Controls and Sanctions 2019,” Practicing Law Institute’s 24th Annual Consumer Financial Services Institute (December 2019)
  • “Expansion of Regulatory Oversight on Overcoming National Security Concerns and Trends,” ACI’s European Forum on Foreign Investment Security Reviews and CFIUS (June 2019)
  • “CFIUS and the Expanding Scope of Foreign Direct Investment Reviews.” PLI One-Hour Briefing (May 2019)
  • “Complying with U.S. Sanctions in a Time of Change,” ACI’s 12th Flagship Conference on Economic Sanctions Enforcement & Compliance (May 2019)
  • “Taking Your Compliance Program to the Next Level,” PLI’s The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2019 (April 2019)
  • “Beyond Europe - The Screening Schemes of Major EU Trade Partners,” A Common European Law on Investment Screening: Foreign Investment in Times of Change (March 2019)
  • “Complying with U.S. Sanctions in a Time of Change,” UNC’s Banking Institute (March 2019)
  • “Real World Contract Management Scenarios: How to Build-in Contingency Plans When Drafting Contracts,” ACI’s 4th Asia Pacific Summit on Economic Sanctions (October 2018)
  • “Real World Compliance Issues and How to Solve Them,” PLI’s The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2018 (April 2018)
  • “Cross-Border Enforcement: US Economic and Trade Sanctions Prosecutions,” American Bar Association’s 32nd Annual National Institute on White Collar Crime (March 2018)
  • “Ethics and Compliance Considerations for Trade Controls Lawyers,” Practicing Law Institute’s Coping with US Export Controls and Sanctions 2017, Washington, DC (December 2017)

Client Alerts (Most Recent)

  • "United States Expands Sanctions Against Russia's Defense-Industrial Sector and Russian Elites" (O'Melveny National Security Alert, March 2022) (with David J. Ribner)
  • "President Biden Signs New Critical Infrastructure Cyber Incident Reporting Obligations Into Law" (O'Melveny Data Security & Privacy Alert, March 2022) (with Tod Cohen, Randall W. Edwards, John Dermody, Joshua Goode)
  • "United States Adds New Sanctions Targeting Russia" (O'Melveny National Security Alert, March 2022) (with David J. Ribner, Dillon Roseen)
  • "Russian Aggression Prompts Senate to Pass Cybersecurity Legislation" (O'Melveny Data Security & Privacy Alert, March 2022) (with Tod Cohen, Randall W. Edwards, John Dermody, Joshua Goode)
  • "United States Expands Sanctions on Russia to Target Energy Sector" (O'Melveny National Security Alert, March 2022) (with David J. Ribner)
  • "Biden Administration Continues to Broaden Economic Sanctions on Russia in Response to Ongoing Aggression in Ukraine" (O'Melveny National Security Alert, March 2022) (with David J. Ribner)
  • "Biden Administration Issues Second Set of Sanctions on Russia Broadly Targeting the Financial and High-Tech Sectors" (O'Melveny National Security Alert, February 2022) (with David J. Ribner)
  • "Biden Administration Issues Initial Set of Sanctions in Response to Russian Invasion of Eastern Ukraine" (O'Melveny National Security Alert, February 2022) (with David J. Ribner)
  • "The US Forced Labor Enforcement Task Force Seeks Public Comment on Implementation of Uyghur Forced Labor Prevention Act" (O'Melveny National Security Alert, February 2022) (with David J. Ribner)
  • "CFIUS Adds New Zealand to List of Countries Eligible for Preferential Treatment and Determines Australia and Canada Meet Requirements for Key CFIUS Exemptions" (O'Melveny National Security Alert, January 2022) (with David J. Ribner)
  • "The Biden Administration Ends the Year with Several National Security-Driven Measures Targeting China" (O'Melveny National Security Alert, December 2021) (with David J. Ribner)
  • "Commerce Clarifies That Technology Supply Chain Rule Reaches 'Connected Software Applications' But Leaves Many Questions Unanswered" (O'Melveny National Security Alert, December 2021) (with John Dermody, Rachel Chung, Lorenzo d'Aubert)
  • "Secure Equipment Act Accelerates FCC Rulemaking to Prohibit Licenses for Chinese Security and Technology Equipment" (O'Melveny Data Security & Privacy Alert, November 2021) (with John Dermody)
  • "CFIUS Extends Deadline for Australia, Canada, and UK to Implement Eligibility Requirements for Key CFIUS Exemptions" (O'Melveny National Security Alert, November 2021) (with David J. Ribner)
  • “The Biden Administration’s Emerging Strategy for Combatting National Security Threats: How Policy Changes May Impact Your Business” (O’Melveny National Security Alert, October 2021) (with John Dermody, David J. Ribner)
  • “It’s a Sign: Key Takeaways from FinCEN’s Ransomware Report” (O’Melveny Data Security & Privacy Alert, October 2021) (with Laurel Loomis Rimon, Braddock Stevenson, John Dermody)
  • “New OFAC Compliance Guidance for the Virtual Currency Industry Provides Insights into OFAC’s Compliance Expectations that are Useful for Both the Virtual Currency Industry and the Broader Corporate Community” (O’Melveny Data Security & Privacy Alert, October 2021) (with David J. Ribner, Laurel Loomis Rimon, John Dermody)
  • “Another Countermeasure—China Adopts Counter-Foreign Sanctions Law” (O’Melveny International Trade Alert, June 2021) (with Walker J. Wallace, Bo Li)
  • “Biden Administration Recalibrates Executive Order Prohibiting Investments in Publicly Traded Securities of Certain Chinese Companies” (O’Melveny International Trade Alert, June 2021) (with David J. Ribner, John Dermody)
  • “Government Imposes Mandatory Cybersecurity Requirements on Pipeline Operators in Response to Ransomware Attack” (O’Melveny Data Security & Privacy Alert, June 2021) (with Tod Cohen, Randall Edwards, Scott Pink, John Dermody)
  • “Biden Executive Order Sets the Table for Industry Cybersecurity Reform” (O’Melveny Data Security & Privacy Alert, May 2021) (with Randall Edwards, Tod Cohen, Scott Pink, John Dermody, Evan Schlom, Rachel Chung)

Enforcement Proceedings and Internal Investigations

  • Conducts internal investigations relating to potential violations of economic sanction laws, antiboycott laws, the FCPA, the Export Administration Regulations (EAR), and the International Traffic in Arms Regulations (ITAR) and Customs rules.
  • Represents US and foreign companies in connection with internal investigations and 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.
  • Recent illustrative examples include:
    • Represented oilfield services company in connection with SEC inquiry related to corruption risks in countries subject to US economic sanctions.
    • Represented engineering firm in connection with internal investigation in the Middle East related to its interactions with employees of state-owned enterprises.
    • Advised digital currency exchange on issues arising from OFAC subpoena.
    • Represented U.S. transportation firm in worldwide DOJ FCPA investigation that led to declination.

Compliance Risk Assessments and Audits

  • Conducts assessments and audits of compliance programs in a variety of industries.
  • Recent illustrative examples include:
    • Conducted an FCPA risk assessment for a US publicly-traded semiconductor manufacturer, with a particular focus on its Asian operations.
    • Managed a worldwide risk assessment for a multinational chemical company covering anti-corruption, economic sanctions, and antitrust laws.

Due Diligence and Post-Investment Planning

  • 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. 
  • Recent illustrative examples include:
    • Advised petrochemical firm on measures and strategies for mitigating anti-corruption risk in prospective minority-held joint venture in China.
    • Assisted private equity firm with developing plan to enhance new portfolio company’s compliance program for anti-corruption, economic sanctions and export controls.
    • Conducted anti-corruption due diligence on Brazilian target for US software company.

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. 
  • Recent illustrative examples include:
    • Advised global chemical company on development of economic sanctions and export control policies.
    • Advised a Chinese manufacturer on the type of  program necessary to comply with the FCPA when the company became an “issuer” for purposes of US securities laws and assisted in the implementation of that program.
    • Assisted a US water treatment company with enhancements to its FCPA compliance program.
    • Assisted a reinsurance broker with establishing worldwide anti-bribery program and training materials.

Licensing, Classifications, and Advisory Opinions 

  • Represents US and foreign 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, Libya, Sudan, and Syria. 
  • Recent illustrative examples include:
    • Licenses authorizing activities associated with terminating operations in Iran
    • Technical Assistance Agreements for defense-related activities
    • Export control authorizations for encryption and oilfield service products
    • OFAC licenses for reinsurance activity
    • Commodity classification ruling requests
    • Commodity jurisdiction filings

Counseling

  • 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, anti-bribery, antiboycott, customs, and anti-money laundering laws.
  • Recent illustrative examples include:
    • Provide advice on anti-bribery risks associated with marketing plans that include the provision of business courtesies to government officials.
    • Advise numerous companies on intermediary due diligence strategies designed to mitigate anti-corruption and economic sanctions risks.
    • Advise on the consequences of changes in economic sanctions laws, including the recent Russia/Ukraine sanctions and changes in the Iran and Cuba sanctions programs.

Government Proceedings and Inquiries 

  • Prepared a number of voluntary notices and mandatory declarations to CFIUS on behalf of both non-US investors and domestic firms.
  • Represented US companies in connection with “focused assessment” audits conducted by the US Bureau of Customs and Border Protection. 

Events

Alerts and Publications

Governor Newsom Vetoes the California BitLicense, Calling It Premature

September 27, 2022

Biden Administration Issues Policy Directive on National Security Reviews of Foreign Investments in U.S. Businesses

September 23, 2022

U.S. Economic Sanctions and Export Controls on Russia and Belarus Expand, with Further Measures Likely

September 22, 2022

From New York to California: The BitLicense Goes Bicoastal

September 21, 2022

New Restrictions on Imports Manufactured With Forced Labor Take Effect

June 24, 2022

Biden Administration Further Expands Sanctions on Russia as War in Ukraine Continues

May 16, 2022

United States Expands Sanctions Against Russia’s Defense-Industrial Sector and Russian Elites

March 25, 2022

President Biden Signs New Critical Infrastructure Cyber Incident Reporting Obligations Into Law

March 22, 2022

United States Adds New Sanctions Targeting Russia

March 14, 2022

Russian Aggression Prompts Senate to Pass Cybersecurity Legislation

March 9, 2022

United States Expands Sanctions on Russia to Target Energy Sector

March 9, 2022

Biden Administration Continues to Broaden Economic Sanctions on Russia in Response to Ongoing Aggression in Ukraine

March 4, 2022

Biden Administration Issues Second Set of Sanctions on Russia Broadly Targeting the Financial and High-Tech Sectors

February 25, 2022

Biden Administration Issues Initial Set of Sanctions in Response to Russian Invasion of Eastern Ukraine

February 23, 2022

The US Forced Labor Enforcement Task Force Seeks Public Comment on Implementation of Uyghur Forced Labor Prevention Act

February 1, 2022

CFIUS Adds New Zealand to List of Countries Eligible for Preferential Treatment and Determines Australia and Canada Meet Requirements for Key CFIUS Exemptions

January 25, 2022

The Biden Administration Ends the Year with Several National Security-Driven Measures Targeting China

December 29, 2021

Commerce Clarifies That Technology Supply Chain Rule Reaches “Connected Software Applications” But Leaves Many Questions Unanswered

December 8, 2021

Secure Equipment Act Accelerates FCC Rulemaking to Prohibit Licenses for Chinese Security and Technology Equipment

November 24, 2021

CFIUS Extends Deadline for Australia, Canada, and UK to Implement Eligibility Requirements for Key CFIUS Exemptions

November 23, 2021

It’s a Sign: Key Takeaways from FinCEN’s Ransomware Report

October 20, 2021

New OFAC Compliance Guidance for the Virtual Currency Industry Provides Insights into OFAC’s Compliance Expectations that are Useful for Both the Virtual Currency Industry and the Broader Corporate Community

October 19, 2021

Another Countermeasure—China Adopts Counter-Foreign Sanctions Law

June 17, 2021

Biden Administration Recalibrates Executive Order Prohibiting Investments in Publicly Traded Securities of Certain Chinese Companies

June 7, 2021

Biden Administration Recalibrates Executive Order Prohibiting Investments in Publicly Traded Securities of Certain Chinese Companies

June 7, 2021

Government Imposes Mandatory Cybersecurity Requirements on Pipeline Operators in Response to Ransomware Attack

June 2, 2021

Biden Executive Order Sets the Table for Industry Cybersecurity Reform

May 17, 2021

Biden Administration Issues New Targeted Economic Sanctions On Russia

April 16, 2021

FCC Lists Certain Chinese Telecom Equipment as National Security Risk

March 17, 2021

Commerce Department’s New Technology Supply Chain Rules Leave Many Unanswered Questions

February 2, 2021

EU Commission Publishes Text of EU-China Comprehensive Agreement on Investment

January 27, 2021

Unfinished Business and Potential New Directions: The Biden Administration Faces Many Decisions in Addressing Trump Administration Measures Targeting China and other National Security Threats

January 20, 2021

China Issues Rules to Counteract “Unjustified” Extra-territorial Application of Foreign Laws

January 15, 2021

Trump Administration Takes Further Actions Targeting China as Term Nears End

December 21, 2020

President Trump Issues Executive Order Prohibiting US Investments in Companies with Ties to the Chinese Military

November 16, 2020

Treasury Issues New Guidance on Risks of Ransomware Payments

October 9, 2020

Preliminary Injunctions Delay Implementation of Commerce Department Orders Targeting TikTok and WeChat

October 1, 2020

Press Releases

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