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- Peter Lichtenbaum
Peter Lichtenbaum advises clients on a broad array of international regulatory compliance and trade matters, including export controls, economic sanctions, national security reviews of foreign investments, anti-corruption laws, market access, and international trade disputes. He has specialized experience in the aerospace and defense industries.
Mr. Lichtenbaum is ranked in Band 1 for Export Controls & Sanctions in Chambers USA (2015), which reports that “clients laud him as ‘a real subject matter expert’ who ‘knows how the regulators think.’” Chambers Global (2015) described him as “a much-praised trade controls attorney, with impressive experience advising on enforcement actions and investigations. Clients prize his ‘clear and balanced advice,’ ‘thorough and thoughtful’ approach and talent for providing ‘high-level, strategic advice.’”
Mr. Lichtenbaum co-chairs Covington’s International Trade and Finance practice. He also co-chairs the firm’s Aerospace and Defense Industry Group, and leads the firm’s Compliance Initiative.
Mr. Lichtenbaum has recently helped several companies establish, review or enhance their compliance programs. He has worked with many leading aerospace and defense companies on internal investigations and disclosures related to trade controls and China. He also advises many of these companies on export control reform and defense trade policy issues, including international agreements on the regulation of defense trade. He has extensive experience with the trade controls issues that arise in the U.S. system for national security review of foreign investment, helping companies to identify issues and mitigate government concerns.
Mr. Lichtenbaum served as Vice President for Regulatory Compliance and International Policy at BAE Systems, Inc., the U.S. subsidiary of one of the world’s largest defense contractors. He was responsible for a broad array of regulatory compliance and policy issues. He participated in BAE Systems’ development of innovative standards of internal governance in order for the company to be recognized as a global leader in ethical business conduct.
Previously, Mr. Lichtenbaum held senior positions in the Department of Commerce, one of three key agencies responsible for administering US trade controls. From October 2003 through February 2006, he served as the Assistant Secretary of Commerce for Export Administration, responsible for developing Bureau of Industry and Security (BIS) policies regarding export controls imposed for national security, foreign policy, nonproliferation, and other reasons. Mr. Lichtenbaum chaired the inter-agency Advisory Committee on Export Policy, and managed BIS’s participation in multilateral export control regimes. He represented the Department of Commerce in many sensitive matters reviewed by the Committee on Foreign Investment in the United States (CFIUS). Mr. Lichtenbaum served for several months as Acting Under Secretary of Commerce for Industry and Security and as Acting Deputy Under Secretary of Commerce for International Trade.
Mr. Lichtenbaum has also managed the development and defense of several major WTO dispute settlement cases, in which he worked closely with the Office of the U.S. Trade Representative and other governments. He advised major companies regarding WTO trade policy matters. He also has significant experience handling a wide variety of countervailing duty and other subsidy matters.
- Advising major personal device manufacturer regarding its trade controls due diligence on target companies.
- Advising large Middle East-based petrochemical company regarding its overall compliance program, including trade controls and anti-corruption.
- Advising U.S.-based private equity fund regarding its due diligence, acquisition and integration of an Asia-based satellite company.
- Advising U.S.-based multinational company in its compliance with U.S. export controls and trade sanctions, including with respect to Russia and Iran.
- Advising large U.S.-based aerospace and defense company regarding its response to U.S. government investigations of export control violations related to China
- Advising major international consultancy in review of its trade controls compliance program.
- Advising large U.S.-based consultancy in review of its trade controls compliance program.
- Advised large multinational company regarding internal investigation and disclosure of dual-use export control violations related to China.
- Advised U.S. helicopter manufacturer regarding CFIUS and export control review and filings in connection with its sale to a Chinese state-owned entity.
- Advised U.S. helicopter manufacturer regarding market access concerns related to government procurement in Latin America.
- Advised major aerospace company regarding settlement of Justice Department and State Department defense export control enforcement cases.
- Led analysis of European dual-use and defense trade controls for major aerospace company with sites in several countries.
- Advised on application of new U.S. and European sanctions on Libya to ongoing business operations of multinational firms.
- Defended individual charged with criminal violations of U.S. dual-use export controls.
- Assisted U.S. aerospace company with export classification and licensing requirements for joint venture with Chinese partner.
- Represented U.S. company in State Department and CFIUS review of asset sale to Chinese purchaser.
Pro Bono
- Advising global pro bono law firm regarding a wide range of international human rights issues, such as restrictions on non-government organizations and land confiscation policies.
Memberships and Affiliations
- U.S. State Department, Defense Trade Advisory Group (DTAG)
- Washington Export Council, Chairman
- American League for Exports and Security Assistance (ALESA), General Counsel
- Defense Export Controls Forum, Steering Committee and former Chairman
- American Bar Association Section of International Law, past co-Chair, Committee on Export Controls and Economic Sanctions
- U.S. Chamber of Commerce, International Policy Committee
- Aerospace Industries Association, International Council (2007-2010)
Previous Experience
- BAE Systems, Inc., Vice President for Regulatory Compliance and International Policy
- U.S. Department of Commerce, Assistant Secretary for Export Administration
- U.S. Department of Treasury, Office of General Counsel (Honors Attorney)
January 2015, Corporate Counsel
December 2010, Coping with U.S. Export Controls
Sanctioning Clarity
December 2011/January 2012, The European Lawyer
March 4, 2011, Georgetown University International Trade Update
July 28, 2017, Covington Alert
Congress has passed and sent to President Trump, for his signature or veto, a bill that would impose significant new sanctions against Russia, Iran, and North Korea. The legislation—the Countering America’s Adversaries Through Sanctions Act—enjoys broad bipartisan support, having passed the U.S. House of Representatives on July 25 by a vote of 419-3, and the ...
June 23, 2017, Covington Alert
We are writing to provide our perspective on recent developments regarding the Committee on Foreign Investment in the United States (“CFIUS”), including the plans of Senator John Cornyn (R-TX) to introduce significant legislation to reform CFIUS, and the operation of CFIUS in the first six months of the administration of President Donald Trump.
U.S. Tightens Cuba Embargo; Senate Passes Iran/Russia Sanctions Bill; Arab Nations Boycott Qatar
June 19, 2017, Covington Alert
On Friday, June 16, 2017, President Donald J. Trump announced a tightening of the United States’ long-standing Cuba embargo, rolling back some of the easing implemented during the Obama Administration and described in our prior client alerts. The Trump Administration’s approach is outlined in a National Security Presidential Memorandum, but the full scope of this policy shift will not be known until the Treasury Department’s Office of Foreign Assets Control (“OFAC”) adopts new regulations in the coming months. As OFAC clarified in its Frequently Asked Questions, none of the changes announced by the President last week take effect until the new regulations are issued.
The U.S. Senate has also passed a bill that would codify existing sanctions and impose new sanctions against Russia, and also impose new sanctions against Iran. This bill now goes to the House of Representatives. Additionally, the boycott of Qatar by Saudi Arabia, the United Arab Emirates, and other countries raises issues under the U.S. antiboycott regimes administered by the U.S. Treasury and Commerce Departments. These recent developments potentially present legal risks for companies operating in Russia and the Middle East.
May 2, 2017, BNA's Federal Contracts Report
Peter Lichtenbaum and Fred Levy are quoted in a Federal Contracts Report article regarding the dispute, which is on appeal in the Fourth Circuit, between South Korea and BAE following the failure to finalize a deal to upgrade the F-16 jet. According to Lichtenbaum, the contracting community would expect the Fourth Circuit not to enforce the BAE-South Korea ...
April 21, 2017, Global Policy Watch
On April 20, 2017, President Trump issued a memorandum announcing that the Secretary of Commerce had initiated an investigation to determine the effects of imported steel on national security. The investigation was initiated under Section 232 of the Trade Expansion Act of 1962, as amended. I. Conduct of Section 232 Investigations Under Section 232, Secretary...… ...
April 21, 2017, Covington Alert
On April 20, 2017, President Trump issued a memorandum announcing that the Secretary of Commerce had initiated an investigation to determine the effects of imported steel on national security. The investigation was initiated under Section 232 of the Trade Expansion Act of 1962, as amended. While it remains to be seen what actions the Administration might ultimately take pursuant to the findings of the Section 232 investigation, the Administration’s invocation of this rarely used trade tool further suggests the Administration's interest in “Buy America” strategies.
February 28, 2017
WASHINGTON—Covington represented semiconductor manufacturer Intersil Corporation in its $3.2 billion sale to Japan’s Renesas Electronics Corporation. The firm advised Intersil on aspects of the transaction involving Committee on Foreign Investment in the United States (CFIUS), Foreign Ownership, Control, or Influence (FOCI), trade controls, and government ...
January 27, 2017, Law360
Law360 selected Covington’s International Trade practice as a “Practice Group of the Year,” profiling the team’s involvement in billions of dollars worth of transactions, Foreign Corrupt Practices Act investigations, and sensitive national security trade reviews. “Our practice in general is distinguished by the sheer number of former senior enforcement officials ...
January 13, 2017, Covington Alert
Over the past few months, the agencies responsible for criminal and civil enforcement of U.S. export control and economic sanctions laws have implemented a number of important changes in their enforcement practices. In October 2016, the U.S. Department of Justice (“DOJ”), National Security Division (“NSD”) published guidance on voluntary self-disclosures of criminal export control and sanctions violations. In June 2016, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) updated its guidance on charging and penalty determinations for civil violations of export control regulations. And effective August 2016 and January 2017, the agencies responsible for civil enforcement of export control and sanctions regulations increased the maximum civil penalties for violations of those regulations. Each of these recent updates is discussed in more detail below.
January 13, 2017, Covington Alert
In response to “positive actions” taken by the Government of Sudan over the past six months, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced today an amendment to the Sudanese Sanctions Regulations (“SSR,” 31 C.F.R. Part 538) that effectively suspends virtually all of the U.S. sanctions against Sudan by authorizing through a general license (hereinafter, the “General License”) all transactions otherwise prohibited by the SSR and two related executive orders (13067 and 13412). The General License will take effect when it is published in the Federal Register, which is scheduled to occur on Tuesday, January 17, 2017.
January 11, 2017, National Defense
Peter Lichtenbaum was a panelist at the National Defense Industrial Association event “Reforming the Security Cooperation Enterprise” and is quoted in a National Defense article regarding the effect the Trump administration may have on foreign military sales. According to Lichtenbaum, it will take some determined efforts to educate the next administration on how ...
Presidential Report Recommends U.S. Action to Counter Chinese Policies in the Semiconductor Industry
January 11, 2017, Covington Alert
Late last week, a group of technology industry leaders, researchers, and former policymakers comprising the President’s Council on Science and Technology (“PCAST”) issued a report entitled Ensuring Long-Term U.S. Leadership in Semiconductors. The report concludes that China is seeking to reshape the global semiconductor industry in a manner that threatens U.S. leadership in that sector. Given the criticality of the semiconductor industry to U.S. national security, the report recommends a three-part strategy to (1) counter Chinese policy actions, (2) improve the business environment for U.S. semiconductor companies, and (3) help “catalyze transformative semiconductor innovation over the next decade.”
October 17, 2016, Covington Alert
Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. trade embargo and continuing a policy shift that the Obama Administration announced in December 2014.
Simultaneous with last Friday’s announcement of these changes, President Obama issued a Presidential Policy Directive that outlines a policy of “normalization” as to U.S.-Cuba relations. The directive states that the embargo — elements of which remain in place — is “outdated” and renews calls for Congress to lift the remaining restrictions.
October 5, 2016
WASHINGTON—Zachary Mears has joined Covington as a Senior Advisor in the Aerospace, Defense, and National Security industry group and the Public Policy and Government Affairs practice. Dr. Mears previously served as the Chief of Staff to the Deputy Secretary of Defense and Deputy Chief of Staff to the Secretary of Defense. He advised the Secretary and Deputy ...
June 9, 2016, Covington Alert
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) yesterday published new Frequently Asked Questions (“FAQs”) that help clarify the scope of certain measures taken by the United States in January to ease its sanctions against Iran in accordance with the Joint Comprehensive Plan of Action (“JCPOA”), the multilateral agreement signed in mid-July 2015 in which Iran agreed to accept certain limitations on its nuclear program in exchange for sanctions relief. In a prior alert, we described this sanctions relief in detail, as well as concurrent guidance that OFAC issued addressing many of its aspects.
May 31, 2016
WASHINGTON—Chambers USA has selected Covington for its 2016 Award for Excellence in International Trade. The Award for Excellence in International Trade is presented at Chambers USA’s annual awards dinner and awarded to one law firm. The award coincides with the release of the Chambers USA 2016 guidebook, in which Covington received a top-tier ranking nationally ...
October 12, 2015, National Defense Magazine
Peter Lichtenbaum is quoted in this National Defense Magazine blog post discussing the push by the Pentagon to attract innovative technology firms and to create new business relationships with the commercial tech sector. Although conversations between government officials and tech leaders are occurring, there are some doubts about the future success of these ...
Pentagon acquisition reform can save lives, experts say
October 5, 2015, Washington Examiner
Co-chair of both the International Trade and Finance practice and Aerospace and Defense Industry Group Peter Lichtenbaum discusses the Pentagon’s defense acquisition reform to ensure more efficient transfer of technology to the armed services. Lichtenbaum stresses the importance by saying that in the past decade of war, American lives were needlessly lost ...
July 15, 2015, Covington Alert
6/12/2015, Covington Alert
Covington Receives Top Tier Rankings from Legal 500 U.S.
June 9, 2015
WASHINGTON, DC, June 9, 2015 — The Legal 500 U.S. has ranked Covington as a top tier firm in nine practice areas and recognized 25 individual attorneys as “Leading Lawyers” in the directory’s 2015 edition. Additionally, Legal 500 recommended 36 Covington practice areas and 156 Covington lawyers. Top tier rankings include: Antitrust - Cartel Antitrust ...
April 28, 2015, Money Laundering Bulletin
January 8, 2015, Global Policy Watch
President Obama’s announcement that the United States is “changing its relationship with the people of Cuba” has been welcomed by many in the business community, who continue to await regulatory amendments that will implement the new policy. (For background on the President’s announcement, please see our client alert of December 17, 2014 and our audio...… ...
Your International Compliance Playbook
January 2015, Corporate Counsel
Covington's Lanny Breuer and Peter Lichtenbaum have authored this article on corporate compliance: The phone rings, and the CEO tells you she’s planning an acquisition of a target that has operations in Europe and Asia. She’s focused on the potential to develop technology 24-7 and get closer to the global customers. Of course, your job is to get regulatory ...
Developments in U.S. and EU Sanctions Against Russia and the Occupied Crimea Region of Ukraine
December 24, 2014, Covington E-Alert
December 17, 2014, Covington E-Alert
December 17, 2014, Covington E-Alert
September 22, 2014, Covington E-Alert
September 13, 2014, Covington E-Alert
August 18, 2014
WASHINGTON, DC, August 18, 2014 — Best Lawyers named Covington & Burling’s Stuart Eizenstat and Gregg Levy each a 2015 “Lawyer of the Year” in international trade and sports law, respectively, citing their “abilities, professionalism and integrity.” Overall, Covington lawyers received 217 individual mentions in 58 areas of law in the newly released annual survey ...
August 15, 2014, Covington E-Alert
August 12, 2014, Covington E-Alert
August 4, 2014, Covington E-Alert
July 23, 2014, Covington E-Alert
July 10, 2014, Covington E-Alert
Covington Receives Top Tier Nods in Legal 500 U.S.
June 26, 2014
WASHINGTON, DC, June 26, 2014 — The Legal 500 U.S. has ranked Covington & Burling in its top tier in eight practice areas and recognized 23 individual attorneys as “Leading Lawyers” in the directory’s 2014 edition. Additionally, Legal 500 “recommended” 42 Covington practice areas and 153 Covington lawyers. The eight Covington practices given the top tier ranking ...
June 26, 2014
WASHINGTON, DC, June 26, 2014 — A report on how the United States uses drones in the national security arena was released today by the Stimson Center’s Task Force on U.S. Drone Policy. Covington & Burling’s Peter Lichtenbaum was a member of the nonpartisan 10-member task force co-chaired by General John P. Abizaid (US Army, Ret.), former Commander of U.S. ...
June 26, 2014, Covington E-Alert
June 23, 2014, Covington E-Alert
May 23, 2014, Covington E-Alert
May 13, 2014, Covington E-Alert
May 12, 2014, Covington E-Alert
April 29, 2014, Covington E-Alert
April 28, 2014, Covington E-Alert
April 15, 2014, Covington E-Alert
March 21, 2014, Covington E-Alert
United States and European Union Impose Additional Sanctions in Response to the Crisis in Ukraine
March 18, 2014, Covington E-Alert
March 6, 2014, Covington E-Alert
March 5, 2014, Covington E-Alert & Advisory
March 4, 2014, Covington E-Alert
How to React to an ITAR Violation: Key Considerations and Best Practices for Disclosure
January 22, 2014, 5th Advanced Forum on ITAR Compliance for European Operations
January 22, 2014, Covington E-Alert
November 27, 2013, Covington E-Alert
August 26, 2013, Covington E-Alert
US, European and French Foreign Trade Controls: Recent Developments
April 16, 2013, Présentation à la Commission internationale: Paris – New York
January 4, 2013, Covington E-Alert
December 28, 2012
BEIJING, December 28, 2012 — Chambers has named Covington & Burling as a finalist for the 2013 Chambers China Awards for Excellence in the International Trade category. The awards recognize preeminence in key practice areas and significant achievements over the past 12 months, including outstanding work, impressive strategic growth and excellence in client ...
December 27, 2012, Covington E-Alert
Five Covington Lawyers Named Law360 MVPs
December 3, 2012
WASHINGTON, DC, December 3, 2012 — Law360 named five Covington & Burling lawyers today as “Most Valuable Players” in their respective practice areas. The award singles out lawyers from across 22 practice areas whose achievements in major litigation or transactional matters have “raised the bar” over the past year. The Covington lawyers recognized as Law360 MVPs ...
August 27, 2012
WASHINGTON, DC, August 27, 2012 — Covington & Burling LLP lawyers received 196 individual mentions in 57 areas of law in the 2013 edition of The Best Lawyers in America. This annual compilation of top U.S. lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as ...
Proposed Amendments to the ITAR Brokering Regulations and Other Recent Export Control Developments
January 3, 2012, Covington E-Alert
December 5, 2011, Covington E-Alert
The Next Step in Export Control Reform: Proposed Revisions to Controls On Military Aircraft Unveiled
November 15, 2011, Covington E-Alert
October 4, 2011, Covington E-Alert
October 4, 2011, Covington E-Alert
September 29, 2011, Covington E-Alert
September 7, 2011
WASHINGTON, DC, September 7, 2011 — Covington & Burling LLP lawyers received 184 individual mentions in 56 areas of law in the 2012 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as follows: ...
September 2, 2011, Covington E-Alert
August 30, 2011, Covington E-Alert
August 19, 2011, Covington E-Alert
Commerce Department Issues Final Rule on the New Strategic Trade Authorization License Exception
July 28, 2011, Covington E-Alert
6/10/2011
WASHINGTON, DC, June 10, 2011 — In presenting Covington & Burling LLP with the Chambers USA Award for Excellence in International Trade on June 9th, Chambers noted how the firm’s “comprehensive team covers the complete spectrum of international trade matters and clients benefit from the close-knit and interdisciplinary approach of the department's various ...
June 2011, International Security Programme Paper, Chatham House
May 16, 2011, Covington E-Alert
April 20, 2011, Financial Times
April 19, 2011, Covington E-Alert
April 12, 2011, Covington E-Alert
February 28, 2011, Covington E-Alert
December 23, 2010, Covington E-Alert
December 16, 2010, Covington E-Alert
October 8, 2010, Covington E-Alert
September 30, 2010, Covington E-Alert
Covington’s International Trade and National Security Practices Expand with Lichtenbaum
August 10, 2010
WASHINGTON, DC, August 10, 2010 — Covington & Burling LLP is pleased to announce that Peter Lichtenbaum, most recently Vice President for Regulatory Compliance and International Policy at BAE Systems, Inc., has joined the firm as a partner. He will be resident in Covington’s Washington office, and will concentrate in the firm’s International Trade and Finance ...
- Law360, International Trade MVP (2012)
- Chambers Global, International Trade (2014-2017)
- Chambers USA - America's Leading Business Lawyers, International Trade: Export Controls & Economic Sanctions (2013-2017)
- Best Lawyers in America (2013-2017)
- Legal 500 US, “Leading Lawyer” - Litigation: International Trade (2014-2017)
- Legal 500 US, Litigation: International Trade (2013-2017)
- Washington DC Super Lawyers, International (2014-2017)
- Who's Who Legal, Trade & Customs (2015)
Industries
Education
Harvard Law School, J.D., 1990
- cum laude
Harvard University, John F. Kennedy School of Government, M.P.P., 1990
Princeton University, Woodrow Wilson School of Public and International Affairs, A.B., 1986
- magna cum laude
- Phi Beta Kappa
Government Service
- U.S. Department of Commerce
- U.S. Department of the Treasury
Bar Admissions
- District of Columbia