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Timothy P. O’Toole

Member – Miller & Chevalier

Phone: 202-626-5552

Timothy P. O’Toole counsels and defends clients in white collar criminal matters, conducts internal corporate investigations, and represents potential witnesses and targets in government investigations. Between his time at Miller & Chevalier and his time in government service, Mr. O’Toole has been conducting and leading large-scale defense investigations for over 20 years. Although Mr. O’Toole has substantial experience in all areas of white collar practice, his main focus is on economic sanctions and export controls. Mr. O’Toole represents companies and individuals at all stages of the process, including defending enforcement actions brought by 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) and the U.S. Department of Justice (DOJ). Mr. O’Toole conducts due diligence investigations regarding trade issues in connection with mergers and acquisitions and represents companies before the Committee on Foreign Investment in the United States (CFIUS). He also provides companies and individuals with advice on compliance with the U.S. economic sanctions and export controls laws, and interacts regularly with OFAC, DDTC and BIS in that capacity.

Mr. O’Toole writes and speaks often about sanctions and export controls at venues and media outlets around the world. He is co-chair of the National Association of Criminal Defense Lawyers (NACDL) West Coast White Collar Crime Conference in Santa Monica and a past co-chair of the NACDL’s White Collar Crime Committee.

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.


  • Represent oil and gas company in world-wide internal investigation of potential violation of North Korea sanctions
  • Conduct world-wide investigation of potential OFAC violations for international trade insurance provider and defend related OFAC subpoena
  • 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 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
  • Represent witness in grand jury proceedings in Iran sanctions matter
  • Defend large international insurance carrier before OFAC in case involving potential violation of Iran sanctions
  • Represent various companies before DDTC in connection with ITAR registration and licensing issues
  • Represent multiple companies submitting application to OFAC for authorization to engage in conduct otherwise prohibited by economic sanctions
  • Advise companies on day-to-day compliance issues involving Cuba, Russia/Ukraine, North Korea, Sudan, and Iran embargoes



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