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Timothy P. O'Toole's white collar defense practice focuses on high-stakes cases involving the economic sanctions, export controls, foreign investment, cybersecurity, and anti-money laundering laws. His clients run the gamut, including U.S. and non-U.S. financial institutions, and public and private companies in the aviation, insurance, logistics, manufacturing, energy, and telecommunications sectors. Recognized as one of the leading international trade lawyers in the U.S. by Chambers USA, Legal 500, Who's Who Legal, and Global Investigations Review, Mr. O'Toole represents companies and individuals at all stages of the process, including compliance, licensing, guidance, and enforcement.  He represents clients in a variety of matters before the Treasury Department's Office of Foreign Asset Control (OFAC), the State Department's Directorate of Defense Trade Controls (DDTC), the Commerce Department's Bureau of Industry and Security (BIS), the Committee on Foreign Investment in the United States (CFIUS), and the U.S. Department of Justice (DOJ). Mr. O'Toole also hosts the firm's economic sanctions and export controls podcast, EMBARGOED!

Prior to joining Miller & Chevalier, Mr. O'Toole served as the Chief of the Special Litigation Division of the Public Defender Service for the District of Columbia where, among other things, he managed and conducted large-scale criminal defense investigations for matters pending in the local and federal courts. He is a former Assistant Federal Public Defender in Las Vegas, Nevada, where he conducted investigations and handled matters for people under sentence of death in federal proceedings.

Representative Engagements
  • Represent oil and gas companies in world-wide internal investigation of potential violation of North Korea sanctions
  • Handle multiple, complex, high stakes OFAC licensing and reconsideration matters
  • Represent clients before OFAC and BIS in enforcement proceedings involving Iran, Russia, Venezuela, North Korea, Cuba and other U.S. sanctions programs 
  • Serve as lead liaison to company seeking to comply with ITAR consent decree imposed by DDTC
  • Gain clearance from CFIUS in multiple foreign investment matters 
  • Defend U.S. carrier against possible enforcement action related to Cuba travel
  • Conduct world-wide investigation of potential OFAC violations for international trade insurance provider and defend related OFAC subpoena
  • Represent large Venezuela-based oil logistics company in licensing and potential enforcement proceedings related to U.S. sanctions against Venezuela
  • In the wake of a Ransomware attack, provide advice and counsel to U.S. manufacturing company about how to analyze and address potential ITAR violations related to the attack
  • Successfully defend natural resources company in the U.K. against potential violations of Cuba sanctions
  • Successfully secure removal of company and two individuals from OFAC blacklists (SDN and FSE lists)
  • Successful pursue OFAC license to secure funds from an SSI in compliance with U.S. sanctions against Russia
  • Successfully represented individual in connection with Grand Jury subpoena in ITAR investigation
  • Prepared and submitted detailed and complex license requests for U.S. manufacturing company to export items to Chinese Military End Users
  • Prepared and submitted detailed and complex license requests to Entity List licensing matters
  • Lead investigation into potential ITAR violations based on exports to China for large client in the aviation sector
  • Manage investigation and response to OFAC subpoena for large travel industry client
  • Represent U.S. manufacturer in handling multiple export controls (EAR and ITAR) matters related to China and other Asian countries, including internal investigations, mergers and acquisition due diligence, voluntary disclosures, product classification filings with BIS, and providing frequent compliance advice
  • Conduct internal investigation and successfully defend U.S. company in enforcement action involving shipments of U.S. goods to Pakistan
  • Investigate and advise on potential U.S. sanctions issues and interact with financial institutions for European manufacturing client exploring Initial Public Offering
  • Conduct internal investigation of potential Iran sanctions violations for large foreign financial institution
  • Defend individual charged with violating Iran Sanctions in criminal proceedings
Government Experience
  • Chief, Special Litigation Division, Public Defender Service for the District of Columbia, 2003 - 2007
  • Staff Attorney, Appellate Division, Public Defender Service for the District of Columbia, 2000 - 2003
  • Assistant Federal Public Defender, Las Vegas, Nevada, 1996 - 2000
  • Appellate Deputy Public Defender, Nevada State Public Defender's Office, 1995 - 1996
Rankings and Recognition
  • Chambers USA: International Trade: Export Controls & Economic Sanctions (Nationwide), 2019, 2021 - 2023
  • Chambers Global: International Trade: Export Controls & Economic Sanctions (USA), 2022 - 2024
  • Legal 500: Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense, 2020 - 2023
  • Legal 500: Dispute Resolution: International Trade, 2017 - 2022
  • Legal 500: Labor & Employment: ERISA Litigation, 2013 - 2017, 2019
  • The Best Lawyers in America®: Criminal Defense: White Collar, 2021 - 2024
  • Global Investigations Review: The 25 Most Respected Sanctions Lawyers in Washington, DC, 2019
  • Who's Who Legal: Trade & Customs - International Sanctions, 2019 - 2021
  • Who's Who Legal: Global Elite Thought Leader (Trade & Customs - International Sanctions), 2020
  • Legal Media Group's Expert Guides: White Collar, 2020
  • DC Bar Capital Pro Bono High Honor Roll, 2013 - 2020
Affiliations
  • Faculty Member, Harvard Law School’s Trial Advocacy Workshop (2017, 2019, 2021)
  • Co-Chair, National Association of Criminal Defense Lawyers' (NACDL) 2nd, 3rd, 4th, 5th, 6th, 7th, 8th, and 9th Annual West Coast White Collar Seminars
  • Vice Chair, Amicus Committee for the DC Circuit, NACDL
  • Member, Death Penalty Representation Project Steering Committee, American Bar Association
  • Immediate Past Co-Chair, White Collar Crime Committee, NACDL
  • Past Member, Board of Directors, NACDL
Admissions
State Admissions
  • District of Columbia
  • California
  • Virginia
Court Admissions
  • United States Supreme Court
  • United States Court of Appeals for the Second Circuit
  • United States Court of Appeals for the Fourth Circuit
  • United States Court of Appeals for the Sixth Circuit
  • United States Court of Appeals for the Seventh Circuit
  • United States Court of Appeals for the Ninth Circuit
  • United States Court of Appeals for the Tenth Circuit
  • United States Court of Appeals for the District of Columbia Circuit
  • United States District Court for the Central District of California
  • United States District Court for the Eastern District of California
  • United States District Court for the Northern District of California
  • United States District Court for the District of Columbia
  • United States District Court for the Eastern District of Michigan
  • United States District Court for the District of Nevada
  • United States District Court for the Eastern District of Virginia
  • United States District Court for the Western District of Virginia
Clerkships
  • Clerk, The Honorable Charles E. Springer, Supreme Court of Nevada
News and Events
Publications