Michael O’Leary*

Partner
moleary@fluet.law

Team Member Profile

Michael O’Leary is a Partner in Fluet’s Government Contracts, International Trade, and Litigation + Investigations Practices, where he leverages his experience both as a federal prosecutor and in private practice to provide strategic counsel on complex regulatory and litigation matters.

Drawing on his prior experience, Mr. O’Leary guides clients through complex legal challenges where business operations meet government oversight and regulation. He represents clients in investigations, enforcement actions, regulatory compliance matters, and disputes in federal and state court with a particular focus on issues relating to economic sanctions, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), customs, foreign investment reviews including the Committee on Foreign Investment in the United States (CFIUS) review process, the False Claims Act (FCA), the Foreign Corrupt Practices Act (FCPA), and anti-money laundering laws. He also counsels entities and individuals regarding registration obligations under the Lobbying Disclosure Act (LDA) and Foreign Agents Registration Act (FARA).

Mr. O’Leary regularly represents companies and individuals in high-stakes government investigations and criminal and civil enforcement actions. He also partners with clients to develop and implement practical risk-based compliance programs that mitigate the risks specific to their business.

As both an advisor and advocate, Mr. O’Leary draws on his prior experience as an Assistant United States Attorney for the Southern District of Florida in Miami where he investigated and prosecuted a wide variety of federal criminal offenses, including bank and wire fraud, identity theft, violent crimes, Medicare fraud, money laundering, violations of the Bank Secrecy Act, and international narcotics trafficking.  During his time as an AUSA, he served as lead counsel or co-lead counsel in sixteen jury trials and handled a number of appeals before the U.S. Court of Appeals for the Eleventh Circuit.  He leverages this prosecutorial background to develop effective defense strategies for clients.

Before joining the U.S. Attorney’s office, Mr. O’Leary served as a judicial law clerk to Judge Cecilia M. Altonaga of the United States District for the Southern District of Florida.

*Michael O’Leary is admitted to practice law in the District of Columbia and New York.

Investigations

  • Represented a major defense contractor in connection with internal investigations of alleged ITAR violations, audits of its export compliance protocols, and voluntary disclosures to the U.S. Government.
  • Represented group of corporate entities and individuals in connection with successful petition for removal from the OFAC SDN list and ancillary federal criminal and forfeiture proceedings.
  • Represented a foreign bank in an internal investigation into alleged violations of OFAC sanctions.
  • Represented a foreign executive in connection with an investigation into alleged economic espionage.
  • Represented multiple Swiss financial institutions and a Swiss professional services firm in connection with investigations related to the DOJ’s Offshore Tax Compliance Initiative.

Litigation

  • Successfully represented entity at trial arising from whistleblower complaint filed by terminated employee.
  • Obtained final judgment on behalf of a group of U.S. service members and their families against Iran after a bench trial in federal court.Represented U.S. Government employees killed and injured in August 1998 bombings of the U.S. Embassies in Nairobi, Kenya and Dar es Salaam, Tanzania in civil actions against entities and governments who supported the attacks.
  • Represented Alaska Native Corporation (ANC) in connection with successful federal court action to ensure ANCs were eligible to receive CARES Act funds.
  • Obtained dismissal of civil complaint against federal defense contractor for breach of contract, fraud, and restraint of trade claims.
  • Represented entity in obtaining a temporary restraining order in trade secrets dispute arising under the Defend Trade Secrets Act.

Compliance Counseling 

  • Counseled a major equipment manufacturer on U.S. export controls and economic sanctions compliance matters.
  • Developed compliance polices and advised multiple clients on anti-money laundering and anti-corruption compliances issues.
  • Advised entity on strategies with respect to federal and state money transmitting licensing issues.
  • Counsels multiple entities and individuals regarding registration obligations under the LDA and FARA.
  • Counseled cryptocurrency company with respect to anti-money laundering and sanctions compliance issues.
  • Counseled non-profit entity with respect to compliance with anti-corruption and sanctions laws.
  • Assistant United States Attorney, United States Department of Justice, Southern District of Florida
  • Law Clerk, Chambers of the Honorable Cecilia M. Altonaga, United States District Court, Southern District of Florida
  • J.D., Columbia Law School, Harlan Fiske Stone Scholar, Columbia Journal of European Law, Editor
  • B.A., History, Vassar College, Graduated with General Honors
  • Visiting Student in Modern History, University of Oxford, St. Peter’s College
  • District of Columbia Bar
  • New York Bar
  • U.S. Courts of Appeals for the District of Columbia
  • U.S. Courts of Appeals for the Second Circuit
  • U.S. District Court for the District of Maryland
  • U.S. District Court for the Eastern District of New York
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the District of Columbia
  • U.S. Supreme Court
  • Officer, Arlington County Council of Parent Teacher Associations (CCPTA)
  • President, Williamsburg Middle School Parent Teacher Association