Timothy P. O'Toole is a Member of Miller & Chevalier and leads the firm's Economic Sanctions & Export Controls Practice. Widely recognized as one of the nation's top sanctions lawyers, he is ranked by Chambers USA, Legal 500, Who's Who Legal, and Global Investigations Review (which named him one of the "25 Most Respected Sanctions Lawyers in Washington, DC").
With more than two decades of experience in high-stakes enforcement and compliance matters, Tim represents leading U.S. and international financial institutions, multinationals, and executives before the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), the Directorate of Defense Trade Controls (DDTC), the Department of Justice (DOJ), and the Committee on Foreign Investment in the United States (CFIUS). His practice covers the full spectrum of sanctions and export controls work, including:
- Advising on complex compliance challenges in Russia, Iran, Cuba, North Korea, and China
- Securing delistings from OFAC's sanctions lists and obtaining licenses to unfreeze blocked funds
- Defending clients in investigations and enforcement actions with billions of dollars at stake
- Guiding companies through cross-border disputes, foreign discovery, and supply chain risk
Tim is an experienced trial and appellate lawyer. Before joining Miller & Chevalier, he served for over a decade as a public defender, including as Chief of the Special Litigation Division at the Public Defender Service for the District of Columbia, where he litigated death penalty and other nationwide complex cases.
A sought-after speaker and thought leader, Tim regularly publishes on sanctions, export controls, and white collar issues, and co-hosts the firm's widely followed trade podcast, EMBARGOED! He serves on advisory boards for leading international sanctions forums and teaches at Harvard Law School's Trial Advocacy Workshop, the American University's Washington College of Law, and the Export Compliance Training Institute (ECTI). He has held senior leadership roles at the National Association of Criminal Defense Lawyers (NACDL).
Tim earned his J.D. from the University of Virginia School of Law and his B.A., cum laude, from the University of Virginia.
- 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
- 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
- Chambers USA: International Trade: Export Controls & Economic Sanctions (Nationwide), 2019, 2021 - 2025
- Chambers Global: International Trade: Export Controls & Economic Sanctions (USA), 2022 - 2025
- 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 - 2025
- 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
- Advisory Board Member, ThoughtLeaders4 Sanctions in Disputes Circle
- 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
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
- Clerk, The Honorable Charles E. Springer, Supreme Court of Nevada