Greta L. Nightingale focuses her practice 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”), money laundering, antiboycott, foreign investment, 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, license requests, and government inquiries. These agencies include the Treasury Department’s Office of Foreign Assets Control, the Securities and Exchange Commission, the Departments of Justice, Commerce and State, and the US Bureau of Customs and Border Protection.
Greta is one of only 12 lawyers to receive top-tier (Band 1) recognition from law firm rankings publication Chambers USA in its International Trade: Export Controls & Economic Sanctions category; Chambers describes her as a “fantastic lawyer” and “well-recognized export controls expert.” In Chambers’ world-wide publication, Chambers Global, Greta ranked again in the top tier (Band 1) for the Export Controls category.
M&A Due Diligence and Post-Investment Planning
- Advises on FCPA, economic sanctions and export controls due diligence within the context of mergers and acquisitions, financings, IPOs, and company expansions into new geographies. Assists with due diligence, appropriate contractual protections and undertakings, as well as post-acquisition planning.
- Represents US and non-US companies in connection with internal investigations and enforcement matters arising from potential violations of economic sanctions, export control and customs, and antiboycott laws, including assisting clients in responding to subpoenas and other information requests from the Department of Justice, the Securities and Exchange Commission, the Commerce Department’s Office of Export Enforcement, OFAC, and in settling pending enforcement matters before such agencies.
- Conducts risk assessments and audits of compliance programs in a variety of industries.
- 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 antiboycott laws.
- 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 in their day-to-day business under anti-bribery, economic sanctions, export controls, and antiboycott laws.
- Represents US and foreign companies in obtaining a range of authorizations, licenses and advisory opinions under the Export Administration Regulations, the International Traffic in Arms Regulations, as well as the economic sanctions regulations governing trade with Cuba, Iran, Iraq, and Libya. Examples include licenses authorizing activities associated with terminating operations in Iran, Technical Assistance Agreements, export control authorizations for encryption and oilfield service products, OFAC licenses for reinsurance activity, commodity classification ruling requests, and commodity jurisdiction filings.
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
Honors & Awards
- Recognized by Best Lawyers® for International Trade and Finance Law in Washington, DC (2025)
- Ranked Band 1 by Chambers Global and Chambers USA in the category of International Trade: Export Controls & Economic Sanctions (2009-2014, 2024-2025; 2016-2024)
- Ranked by Chambers USA in the category of International Trade: CFIUS Experts (2022-2024)
- Recognized by Chambers Global for International Trade: CFIUS Experts (2022, 2024-2025)
- Recognized as a "Leading Lawyer" by The Legal 500 US for International Trade: CFIUS (2014-2024)
- Named one of Global Investigation Review’s “25 Most Respected Sanctions Lawyers” in Washington, DC (2019)
- Recommended in Trade & Customs (2018-2019); Trade & Customs - International Sanctions (2019) by Who’s Who Legal
- Named a “Super Lawyer” in International Law in Super Lawyers - Washington, DC edition (2013-2014; 2017)
- 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)
Professional Activities
Publications
- “Managing Humanitarian Activities During Sanctions,” Export Compliance Manager, Issue 41 (March 2024)
Speaker
- "A Deep Dive Into Russia Sanctions: A Comprehensive Look at the Key Differences between US, UK and EU Restrictions," 17th Annual Flagship Conference on US Economic Sanctions Enforcement and Compliance (April 2023)
Client Alerts (Most Recent)
- “CFIUS Plans to Enhance and Expand Monitoring and Enforcement Authorities” (O’Melveny National Security Alert, April 2024) (with David J. Ribner)