Greta Lichtenbaum’s practice focuses on compliance with US laws that govern international business transactions and trade. Greta 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 describes 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.”
Experience:
- 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.
- 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 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
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
Cost
Rate : $$$