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- Home
- Professionals
- 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 (2019), which reports that he is “one of those rare lawyers who thinks through all the options moving forward.” Chambers describes him as a “go-to lawyer for those with export controls and sanctions issues.”
Mr. Lichtenbaum has recently helped several companies establish, review or enhance their compliance programs. He is advising major technology companies regarding the impact of recent and ongoing export control developments on their businesses. 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 U.S. trade controls. From October 2003 through February 2006, he served as the Assistant Secretary of Commerce for Export Administration, responsible for developing 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.
- Advising multiple U.S. and international technology companies regarding the impact of recent Entity List designations on their operations.
- Advising large U.S.-based software company regarding its compliance with deemed export controls under the EAR and ITAR.
- Conducting risk assessment of large U.S.-based technology company’s export controls and sanctions compliance program.
- Advising large U.S.-based defense company regarding the implementation of a compliance agreement under the ITAR.
- Advising large U.S.-based aerospace and defense company regarding licenses to support international civil aerospace development
- Advising large European-based aerospace and defense company regarding compliance with the EAR and ITAR.
- Advising large Middle East-based petrochemical company regarding its overall compliance program, including trade controls and anti-corruption.
- Advising U.S.-based multinational company in its compliance with U.S. export controls and trade sanctions, including with respect to Russia and Iran.
- Advised large U.S.-based aerospace and defense company regarding its response to U.S. government investigations of export control violations related to China.
- Advised major international consultancy in review of its trade controls compliance program.
- Advised 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 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.
- 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.
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)
December 2010, Coping with U.S. Export Controls
March 4, 2011, Georgetown University International Trade Update
February 8, 2021, Covington Alert
On February 1, 2021, the Myanmar military seized control of the government, detaining senior civilian leaders including State Counsellor Aung San Suu Kyi and President Win Myint. The UN Security Council, G7, and multiple governments condemned the coup and called for the release of civilian leaders. The United States determined that the military’s actions ...
January 29, 2021, Covington Alert
On January 20, 2021, U.S. presidential power transferred—peacefully—to Joseph R. Biden. Presidential transitions historically have brought near-term uncertainty for parties undertaking mergers and acquisitions in the United States, particularly transactions subject to review by the Committee on Foreign Investment in the United States (CFIUS). It typically takes ...
January 22, 2021, Covington Alert
On January 19, 2021, the Department of Commerce (“Commerce”) published an Interim Final Rule to implement provisions of Executive Order 13873, “Executive Order on Securing the Information and Communications Technology and Services Supply Chain” (May 15, 2019) (the “ICTS Order”). Unless suspended by the Biden Administration, the Rule will go into effect 60 days ...
January 22, 2021
WASHINGTON / SAN FRANCISCO— The BTI Consulting Group has named Covington lawyers James Garland, Corinne Goldstein, Benedict Lenhart, Peter Lichtenbaum, Clara Shin, and Sarah Wilson to its 2020 “Client Service All-Stars” list, which recognizes “attorneys who stand above all the others in delivering the absolute best in client service.” Mr. Garland, based in ...
December 21, 2020, Covington Alert
On December 18, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a Final Rule (“the Rule”), effective immediately, adding 77 entities to the BIS Entity List. The majority of these entities are in China, and include, among others, the Semiconductor Manufacturing International Corporation (“SMIC”) and the drone company SZ DJI ...
November 16, 2020, Covington Alert
On Thursday, November 12, 2020, President Trump signed an Executive Order (the “Order”) that, beginning on January 11, 2021, will prohibit U.S. persons from transacting in the publicly traded securities of 31 companies that the Department of Defense has identified as “Communist Chinese military companies.” The requirement for the Department of Defense to create ...
October 14, 2020, Covington Alert
On October 8, 2020, the United States Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the imposition of comprehensive sanctions against 18 major Iranian banks. As part of the same action, the Treasury Department identified the “financial sector” of the Iranian economy as subject to sanctions under Executive Order No. 13902 (the ...
September 22, 2020, Covington Alert
On September 15, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a final rule (the “Final Rule”) amending the requirement to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop one or ...
September 21, 2020, Covington Alert
On September 19, 2020, China’s Ministry of Commerce ("MOFCOM") issued regulations that provide new details on the government’s plans for an “Unreliable Entity List” first proposed in May 2019.
August 20, 2020, Covington Alert
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding its review of certain transactions involving foreign investment during 2019. The current Annual Report was released just two and a half months after the previous Annual Report, covering 2018, demonstrating the Committee has ...
August 20, 2020, Covington Alert
On August 17, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) released a Final Rule (the “August 17 Final Rule”) significantly expanding U.S. export controls restrictions on certain non-U.S. items reexported, exported from abroad, or transferred (in-country) in transactions involving Huawei or its affiliates designated on the BIS Entity ...
July 16, 2020, Covington Alert
In our client alert of May 29, 2020, we reported on the initial U.S. government reaction to the announced intention of China’s legislature, the National People’s Congress (“NPC”), to unilaterally impose national security legislation on Hong Kong. As expected, on June 30, the NPC unanimously adopted the “Law of the People’s Republic of China on Safeguarding ...
July 8, 2020, Covington Alert
In recent years and with increased vigor in recent months, stakeholders and governments, including the United States, have focused on labor-related and other human rights issues concerning the treatment of Uyghur and other minority Muslim groups in the Xinjiang region of China. In this post, we provide an overview of some of these developments and considerations ...
June 9, 2020, Global Policy Watch
It has been publicly reported that discussions are underway within the Trump Administration for a coordinated interagency initiative to remove key industrial supply chain dependencies from overseas, especially China, and redouble efforts to secure such supply chains in the United States. While this initiative proceeds alongside ongoing efforts to secure supply ...
June 9, 2020, Covington Alert
It has been publicly reported that discussions are underway within the Trump Administration for a coordinated interagency initiative to remove key industrial supply chain dependencies from overseas, especially China, and redouble efforts to secure such supply chains in the United States. While this initiative proceeds alongside ongoing efforts to secure supply ...
May 29, 2020, Covington Alert
On May 27, Secretary of State Michael Pompeo certified to Congress pursuant to the Hong Kong Human Rights and Democracy Act of 2019 that "Hong Kong does not continue to warrant treatment under United States laws in the same manner as U.S. laws were applied to Hong Kong before July 1997." In a statement, Secretary Pompeo attributed this action to the announced ...
May 21, 2020, Covington Alert
In an effort to curtail access by China’s Huawei Technologies Co., Ltd. to products made using U.S. semiconductor software and technology, the Commerce Department’s Bureau of Industry and Security (“BIS”) on May 15, 2020, released an Interim Final Rule expanding and extending U.S. export controls jurisdiction to certain non-U.S. items when destined for Huawei or ...
CFIUS Proposes New Rules Governing Mandatory Filing Requirements for Critical Technology Businesses
May 21, 2020, Covington Alert
On May 21, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a proposed rule (the “Proposed Rule”) that would amend the requirements to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop ...
May 19, 2020, Covington Alert
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding foreign acquisitions of, and investments in, U.S. businesses reviewed by CFIUS in 2018. The Committee also released a table reflecting data on the total number of formal reviews (not declarations) in 2019.
April 29, 2020, Covington Alert
The day we have all been expecting has finally come — CFIUS filing fees are going into effect on May 1, 2020. As discussed in our earlier alert, on March 4, 2020, the Department of the Treasury (“Treasury”) issued a proposed rule regarding CFIUS filing fees, which were authorized under the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). ...
April 29, 2020, Covington Alert
On April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule to modify certain license exceptions and definitions in the Export Administration Regulations (“EAR”) (15 CFR Parts 730 – 774), based on concern that sensitive products and technologies were being diverted to military uses ...
April 8, 2020, Covington Alert
On Saturday, April 4, 2020, the White House released the long-awaited Executive Order (“EO”) formalizing the “Team Telecom” Process, titled the “Executive Order on Establishing the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector” (“the Committee”). This EO provides, for the first time, formal ...
April 2, 2020, Covington Alert
The U.S. Department of Commerce (“Commerce”) recently published a new rule which makes it much more likely that the agency will investigate currency undervaluation as a countervailable subsidy. The new rule applies to countervailing duty (“CVD”) investigations or administrative reviews initiated on or after April 6, 2020. Under this new rule, Commerce could ...
April 1, 2020, Covington Alert
The scope and scale of recent events is almost inconceivable. All of us —including the Committee on Foreign Investment in the United States (“CFIUS”) — are sailing in uncharted waters. That said, while we may not have all of the answers, we are able to share some insights from the CFIUS front lines regarding how the challenges presented by the COVID-19 pandemic ...
March 9, 2020, Covington Alert
As we reported this past Friday, on March 6, 2020, President Trump issued only the sixth Executive Order (the “Order”) in history formally prohibiting the acquisition of a U.S. business by a foreign person, pursuant to the authorities that allow the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) to review foreign mergers and ...
The Department of the Treasury Issues Proposed Regulations to Impose Fees for Certain CFIUS Filings
March 4, 2020, Covington Alert
Filing fees — one of the long awaited (and dreaded) innovations of the 2018 Foreign Investment Risk Review Modernization Act (FIRRMA) that has transformed the Committee on Foreign Investment in the United States (CFIUS) — have finally arrived. For more than 30 years, transactions could be submitted to CFIUS for review without a fee payable to the federal ...
January 15, 2020, Covington Alert
On January 10, 2020, President Trump issued a new Executive Order (“January 10 Executive Order”) that provides authority for the imposition of sanctions with respect to certain additional sectors of Iran’s economy, including Iran’s construction, mining, manufacturing, and textiles sectors. The January 10 Executive Order introduces both property-blocking ...
January 14, 2020, Covington Alert
The institutional transformation of the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) that commenced more than two years ago with the introduction in Congress of the Foreign Investment Risk Review Modernization Act (FIRRMA) now is largely complete with the issuance of the highly anticipated final regulations implementing ...
December 9, 2019
The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) released its Annual Report to Congress regarding foreign acquisitions of U.S. businesses reviewed by CFIUS in 2016 and 2017, a combined report covering the final year of the Obama administration and the first of the Trump administration. The report also reflects the crucial ...
November 27, 2019, Covington Alert
The Department of Commerce (“the Department”) has issued a proposed rule implementing the May 15, 2019 Executive Order entitled “Securing the Information and Communications Technology and Services Supply Chain,” which we previously analyzed here. Once finalized and effective, the regulations will govern the process and procedures that the Secretary of Commerce ...
October 10, 2019, Covington Alert
On October 9, the U.S. Department of Commerce issued a Final Rule adding 20 Chinese government entities and eight Chinese private sector entities (“Listed Entities”) to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”).
October 2, 2019, Global Policy Watch
On 4 September 2019, the U.S. Department of State (“DoS”) published draft ‘Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or Parts/Know-How’ (the “Guidance”). The DoS invited public comment on the draft Guidance until 4 October 2019, after which they will publish finalised guidance. Goal: Preventing Human Rights ...
April 2020
For over 30 years, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) focused on a narrow subset of M&A transactions and investments. That era is coming to an end. Covington is monitoring developments: CFIUS Publishes Final Rule Governing Mandatory Filing Requirements for Critical Technology Businesses, Covington ...
September 27, 2019
Last week the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) issued its proposed final regulations (“Regulations”) to implement its expanded authorities under the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). In doing so, CFIUS bifurcated the rulemaking process, proposing one set of regulations to govern ...
September 20, 2019
For over 30 years, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) focused on a narrow subset of M&A transactions and investments. That era is coming to an end. On Tuesday of this past week, CFIUS issued its anticipated proposed final regulations (“Regulations”) to implement the Foreign Investment Risk Review Modernization ...
September 10, 2019
The U.S. Department of the Treasury is expected to issue soon proposed regulations implementing the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation enacted in August 2018 that reformed the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). FIRRMA transformed CFIUS’s authorities, but many of the most ...
August 22, 2019
WASHINGTON—Covington announced that the firm will be serving as part of an international team of lawyers representing media pioneer Maria Ressa, CEO, Cofounder and Executive Editor of Rappler, one of the leading online news platforms in the Philippines, as well as representing Rappler itself. Covington will be serving as U.S. counsel and will coordinate as ...
August 20, 2019, Covington Alert
On August 19, 2019, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a Final Rule adding 46 non-U.S. affiliates of Huawei Technologies Co., Ltd. (“Huawei”) to the Entity List and extended, through November 18, 2019, a revised Temporary General License (“TGL”) authorizing certain transactions with Huawei and listed Huawei entities.
August 8, 2019, Covington Alert
On August 5, 2019, President Trump issued Executive Order 13884 imposing comprehensive sanctions against the Government of Venezuela. Specifically, the Executive Order blocks all property and interests in property of the Government of Venezuela that are in or that come into the United States or the possession or control of a U.S. person.
The National Law Journal - General Litigation Winner
June 3, 2019, The National Law Journal
May 17, 2019, Covington Alert
The U.S. Department of Commerce yesterday issued a Final Rule adding Huawei Technologies Co., Ltd. (“Huawei”) and 68 non-U.S. Huawei affiliates to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”). While the rule will not be published in the Federal Register until May 21, it was effective immediately upon release ...
May 16, 2019, Covington Alert
We are writing to provide an update on two important developments in U.S. national security-based regulation of trade: (1) a new, potentially expansive Executive Order on information and communications technology supply into the U.S. market, and (2) the Department of Commerce’s action to add Huawei to the Entity List.
May 7, 2019, Covington Alert
We are writing to provide an update on the current trends and operations of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). Approximately nine months after the enactment of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) and six months into the Critical Technology Pilot Program (“the Pilot ...
April 25, 2019, Global Policy Watch
The U.S. government is now considering how to define potential new export controls on “emerging technologies.” Our article in the China Business Review explains the legislative context informing the current rulemaking process, highlights key themes in public comments submitted by stakeholders in response to an initial request for input, and offers ...
April 25, 2019, Covington Alert
The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.
April 3, 2019, Covington Alert
In February 2019, the U.S. Department of Justice (“DOJ”) announced a settlement with Honda Aircraft Company LLC regarding claims that Honda Aircraft violated the Immigration and Nationality Act (“INA”) by discriminating against non-U.S. citizens in an attempt to comply with requirements of the International Traffic in Arms Regulations (“ITAR”) and the Export ...
January 29, 2019, Covington Alert
November 20, 2018, Covington Alert
On November 19, 2018, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the criteria to identify emerging technologies essential to U.S. national security. The comments will inform the interagency process that was authorized under the Export Control ...
November 6, 2018, Covington Alert
The Trump Administration yesterday completed the reimposition of sanctions against Iran that previously were suspended as part of the 2015 multilateral nuclear agreement, known as the Joint Comprehensive Plan of Action (“JCPOA”).
October 11, 2018, Covington Alert
Summary On October 10, the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued interim rules (the “Interim Rules”) that update the CFIUS regulations to address certain definitional and procedural aspects of the Foreign Investment Risk Review Modernization Act (“FIRRMA”) and, for the first time, ...
September 5, 2018, The Review of Securities & Commodities Regulation
August 30, 2018, Covington Alert
On August 27, 2018, the Department of State imposed sanctions against Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s use of a chemical nerve agent against a UK citizen.
August 13, 2018, Covington Alert
Earlier today, President Donald Trump signed into law the Foreign Investment Risk Review Modernization Act (FIRRMA) as part of the John S. McCain National Defense Authorization Act. As we have previously reported, FIRRMA will transform the jurisdiction, authority, and operation of the Committee on Foreign Investment in the United States (CFIUS). Our previous ...
August 8, 2018, Covington Alert
On August 6, 2018, President Trump issued Executive Order 13846 (the “Executive Order”) that re-imposes -- and to a limited extent broadens the scope of -- certain U.S. secondary sanctions targeting Iran that had been suspended in January 2016 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran.
July 30, 2018, Covington Alert
On July 23, the final text of the Export Control Reform Act of 2018 (“ECRA”) was released as part of the Conference Report to accompany the National Defense Authorization Act (“NDAA”) for fiscal year 2019. The NDAA is a must-pass piece of legislation that authorizes funding for the Department of Defense, and we expect it to be enacted and signed within the next ...
July 25, 2018, Covington Alert
Summary For over a year, we have reported to our clients as the U.S. government considered and developed legislation that would fundamentally reform the operations of the Committee on Foreign Investment in the United States (CFIUS). That effort has been driven by concerns about risks arising from evolving foreign investment composition and business ...
July 2, 2018, Covington Alert
In furtherance of President Trump’s May 8, 2018 announcement that the United States is withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) (discussed in our recent alert), on June 27 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several changes to the U.S. sanctions against Iran.
June 27, 2018, Covington Alert
We write to report on two important developments regarding the Foreign Investment Risk Review Modernization Act (FIRRMA), a bi-partisan effort to reform the Committee on Foreign Investment in the United States (CFIUS), and the broader policy debate within the U.S. government on regulatory mechanisms to address foreign investment, particularly from China. On June ...
June 15, 2018, Covington Alert
As described in our May 9, 2018, alert, the United States determined on May 8, 2018, to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK, and China.
June 11, 2018, Washington Times
Peter Lichtenbaum is quoted in a Washington Times article regarding U.S. policy on drone strikes. “We can set whatever rules we want, but we need to understand that we are setting a precedent, and other countries are watching very closely what we do,” says Lichtenbaum. “If we assert a certain prerogative, that will make it difficult for us to argue against other ...
May 23, 2018, Covington Alert
Summary We are writing to report the latest developments related to legislative reform of the Committee on Foreign Investment in the United States (“CFIUS”). On Tuesday, May 22, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“Senate Banking Committee” or “SBC”) held a markup of S. 2098—the Foreign Investment Risk Review Modernization Act ...
May 16, 2018, Covington Alert
We are writing to report on the current status of the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation to reform the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). FIRRMA, a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House, seeks to ...
May 15, 2018, Covington Alert
On May 8, 2018, the United States announced the decision to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK and China.
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 8, 2018, Covington Alert
It has been publicly reported that the Trump Administration is considering invoking the International Emergency Economic Powers Act (IEEPA) to further regulate—and in certain areas potentially preclude—Chinese direct investment in the United States, beyond the authorities exercised by the Committee on Foreign Investment in the United States (CFIUS). The prospect ...
April 30, 2018, Covington Alert
We are writing to report on the latest Congressional hearing related to reform of the Committee on Foreign Investment in the United States (“CFIUS”). On April 26, 2018, the Digital Commerce and Consumer Protection Subcommittee of the House Committee on Energy and Commerce (the “Subcommittee”) held an open hearing entitled “Perspectives on Reform of the CFIUS ...
April 20, 2018, Covington Alert
On April 15, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) lifted its suspension of a denial order against two companies, Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun,” and together with ZTE Corporation, ...
April 17, 2018, Covington Alert
We are writing to report on the latest Congressional hearing related to reform of the Committee on Foreign Investment in the United States (“CFIUS”). On April 12, 2018, the Monetary Policy and Trade Subcommittee of the House Committee on Financial Services (the “Subcommittee”) held an open hearing entitled “H.R. 4311, the Foreign Investment Risk Review ...
April 6, 2018, Covington Alert
On April 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced expanded sanctions against Russian entities and individuals, targeting a number of Russian oligarchs in the energy, banking, and other sectors and companies they own or control, as well as 17 senior Russian government officials.
March 16, 2018, Covington Alert
Summary We are writing to report on the latest Congressional hearings related to reform of the Committee on Foreign Investment in the United States (“CFIUS”) and potential efforts to enhance and reform the U.S. export control regime. Specifically, on March 14, 2018, the House Committee on Foreign Affairs (“House Foreign Affairs Committee” or “HFAC”) held an ...
March 8, 2018, Global Policy Watch
On February 15, 2018, House Foreign Affairs Committee Chairman Ed Royce (R-CA) introduced bipartisan legislation—the Export Control Reform Act of 2018 (“ECRA”)⸺to modernize U.S. export control regulation of commercial and dual-use items. The bill is co-sponsored by the committee’s ranking Democratic member, Eliot Engel (D-NY). The proposed legislation seeks to ...
March 8, 2018, Covington Alert
On February 15, 2018, House Foreign Affairs Committee Chairman Ed Royce (R-CA) introduced bipartisan legislation—the Export Control Reform Act of 2018 (“ECRA”)⸺to modernize U.S. export control regulation of commercial and dual-use items.
January 29, 2018, The Litigation Daily
The Litigation Daily highlights Covington's successful representation of Bombardier before the International Trade Commission (ITC). After finding that Bombardier's C-Series commercial jets are not threatening to U.S. producer Boeing, the ITC struck down a planned 300-percent tariff on the Canadian jetliners. "The unanimous decision in our favor was particularly ...
January 26, 2018, Covington Alert
We are writing to report on the latest significant developments in the effort to reform the Committee on Foreign Investment in the United States (“CFIUS”). On January 25, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“Senate Banking Committee” or “Committee”) held an open hearing entitled “CFIUS Reform: Administration Perspectives on the ...
January 26, 2018
WASHINGTON—Covington won a significant trade case today before the U.S. International Trade Commission (ITC) on behalf of its client Bombardier. In a 4-0 ruling, the ITC rejected Boeing Co.’s complaint that it was threatened with material injury by imports of Bombardier’s new C Series aircraft. The decision means that the U.S. Department of Commerce can no ...
January 22, 2018, Covington Alert
On January 18, 2018, the Senate Committee on Banking, Housing, and Urban Affairs (“the Committee”) held a hearing to consider the Foreign Investment Risk Review Management Act (FIRRMA), a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House to reform the Committee on Foreign Investment in the United ...
January 19, 2018, Law360
Covington was named a 2017 International Trade Group of the Year by Law360. According to Peter Lichtenbaum, the Bombardier trade remedies case, which "presents very significant economic, legal, and political issues," was one of the group's biggest from the past year. "The company remains confident that the ITC will conclude that Boeing will not be harmed by the ...
January 11, 2018, Covington Alert
We are writing to share our report of two Congressional hearings held this week that are relevant to the ongoing legislative discussion concerning potential reform of the Committee on Foreign Investment in the United States (CFIUS).
December 15, 2017, Covington Alert
We write to offer our perspective on two developments relevant to the Committee on Foreign Investment in the United States (“CFIUS”).
November 13, 2017, Covington Alert
On Thursday, November 9, 2017, the U.S. Departments of Treasury and Commerce published regulatory amendments that impose new restrictions on financial, travel, and trade-related transactions with Cuba by persons subject to U.S. jurisdiction.
November 9, 2017, Global Policy Watch
During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and...… Continue ...
November 8, 2017, Covington Alert
Earlier today, Senator John Cornyn (R-TX), the second-highest-ranking Republican in the Senate, introduced a bill to reform the authority and operation of the Committee on Foreign Investment in the United States (“CFIUS”). The bill is co-sponsored by Senator Dianne Feinstein (D-CA) and Senator Richard Burr (R-NC), the Chairman of the Senate Select Committee on ...
November 8, 2017, Covington Alert
During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and signed by ...
October 17, 2017, Covington Alert
On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not ...
September 22, 2017, Covington Alert
President Trump has issued an Executive Order (“the Order”), effective September 21, 2017, imposing additional sanctions on persons doing business in certain sectors of the North Korean economy or engaging in certain trade or financial activities involving North Korea. President Trump issued the Order in response to North Korea’s recent intercontinental ...
Newly-Released CFIUS Annual Report for 2015 Foreshadows Heightened Scrutiny of Foreign Investment
September 21, 2017, Covington Alert
The Committee on Foreign Investment in the United States (“CFIUS”) this week released its long-awaited Annual Report to Congress regarding foreign acquisitions of U.S. businesses reviewed by CFIUS in 2015. The report provides important data that yields insights into the types of transactions the Committee reviewed and the Committee’s treatment of those ...
September 14, 2017, Covington Alert
We are writing to provide our perspective on two significant developments involving the Committee on Foreign Investment in the United States (“CFIUS”).
August 29, 2017, Covington Alert
Last week, President Trump issued an Executive Order imposing new economic sanctions on the Venezuelan government in response to President Nicolás Maduro’s increasingly authoritarian actions. The new sanctions expand the U.S. restrictions against Venezuela, which previously were comprised of sanctions against a few key individuals, but they do not amount to a ...
Covington Advises Aristocrat in Acquisition of Plarium and Related Acquisition Financing
August 15, 2017
WASHINGTON—Covington, together with Israeli-based law firm Allens and Herzog Fox & Neeman, is representing Aristocrat Leisure Limited, a leading provider of gaming solutions, in its acquisition of Plarium Global Limited and the related acquisition financing. Aristocrat will make an upfront cash payment of $500 million plus earn-out payments based on Plarium’s ...
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 ...
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 ...
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
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 ...
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 ...
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. ...
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. ...
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 ...
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 ...
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
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 23, 2014, Covington E-Alert
May 23, 2014, Covington E-Alert
May 12, 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 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
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 ...
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
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
April 19, 2011, Covington E-Alert
April 12, 2011, Covington E-Alert
February 28, 2011, Covington E-Alert
December 23, 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 ...
- Mr. Lichtenbaum was recognized by GIR as one of the 25 most respected sanctions lawyers in Washington, DC (2019).
- Law360, International Trade MVP (2012)
- Chambers Global, International Trade (2014-2020)
- Chambers USA - America's Leading Business Lawyers, International Trade: Export Controls & Economic Sanctions (2013-2020)
- Best Lawyers in America (2013-2020)
- Legal 500 US, “Leading Lawyer” - Litigation: International Trade (2014-2017)
- Legal 500 US, Litigation: International Trade (2013-2017)
- The BTI Consulting Group, “Client Service All-Stars” (2020)
- Washington DC Super Lawyers, International (2014-2020)
- Who's Who Legal, Trade & Customs (2015)

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