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CFIUS and the Newly Expanded Scope of Foreign Direct Investment Reviews


Speaker(s): Anne W. Salladin, Greta Lichtenbaum
Recorded on: Mar. 5, 2020
PLI Program #: 296356

Anne Salladin assists foreign and domestic clients in various industries in connection with matters involving national security and cross-border transactions, in particular before the Committee on Foreign Investment in the United States (CFIUS).

Anne dedicated nearly 20 years of service to the Office of the Assistant General Counsel for International Affairs of the Treasury Department, which provides legal advice to the Secretary of the Treasury as Chairperson of CFIUS. As senior counsel, she was responsible for providing legal advice on CFIUS matters, working closely with other CFIUS agencies, played a role in developing laws and regulations related to CFIUS, and participated in the review and investigation of well over 500 transactions filed with CFIUS, including many major Chinese acquisitions.

In addition to her foreign investment work, Anne worked on government-to-government arrangements tied to the Mexican and Asian financial crises and worked extensively on matters relating to sovereign wealth funds. She also has significant experience in sovereign debt restructuring involving Argentina, Greece, and other countries. Anne was part of the G-10 working group focused on sovereign debt documentation designed to facilitate orderly resolution of sovereign debt crises.

In recognition of her significant contributions during her Treasury career, in particular her work on national security issues, Anne received the Secretary's Meritorious Service Award. The award citation notes that she was "indispensable in helping CFIUS to protect U.S. security in dozens of complex transactions" and is "widely acknowledged as an expert on sovereign debt, and a key player in the U.S. efforts to secure global economic stability through the design of sovereign debt restructuring regimes."


Greta Lichtenbaum is a partner in the Washington, DC office of O’Melveny specializing in compliance with US laws that govern international business transactions and trade, including US economic sanctions, export controls, anti-corruption, foreign investment, money laundering, antiboycott, and customs laws.

In addition to advising clients on the application of these laws, Greta assists 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.

Greta has repeatedly been recognized as a leading lawyer in the area of export controls and economic sanctions by Chambers USA (Band 1), Chambers Global (Band 1) and The Legal 500 US. She is a frequent speaker on topics related to international trade and has written extensively on these topics.

Greta graduated from Harvard Law School in 1990. While in law school, she served as Managing Editor of the Harvard Human Rights Journal and a member of the International Law Society.