As a member of the firm’s nationally recognized Government Investigations and White Collar Litigation department, Pat’s practice focuses on criminal and civil enforcement proceedings and internal investigations. He has substantial experience in international and national security matters. He has represented individuals and companies in a variety of federal criminal investigations, as well as civil enforcement actions. He also advises corporate clients on compliance with the Foreign Corrupt Practices Act, OFAC sanctions, the ITAR, the EAR and CFIUS regulations. He has conducted numerous internal investigations for large companies with significant international operations.
Pat spent 18 years in the Department of Justice (DOJ). He most recently served as Assistant Attorney General for National Security. In that Senate-confirmed position, Pat led the National Security Division (NSD), which was formally created by statute in 2006 to bring together all of DOJ’s national security operations under a single authority. As part of his duties, he supervised DOJ’s national security investigations and prosecutions, including all of DOJ’s prosecutions for violations of OFAC sanctions and export controls. In addition, he managed the government’s practice before the Foreign Intelligence Surveillance Court; the coordinated nationwide counterterrorism enforcement program; and the administration of the Foreign Agents Registration Act (FARA). He also oversaw DOJ’s review of foreign acquisitions of U.S. companies through the interagency Committee on Foreign Investment in the United States (CFIUS).
He previously served as the Principal Deputy Assistant Attorney General for the NSD. As the Principal Deputy, he directed the launch and implementation of a nationwide export enforcement initiative, an interagency effort to target the illegal export of sensitive technology and weapons components.
Pat gained extensive courtroom experience while serving as an assistant U.S. attorney for more than 10 years in Washington, D.C. During his tenure, he handled more than 60 jury trials and a number of arguments before the District of Columbia Circuit Court of Appeals and the District of Columbia Court of Appeals.
Experience
- Counsel conducting internal investigation of foreign financial institution in connection with potential violations of OFAC regulations.
- Representation of then-Vice President Mike Pence in special counsel Robert Mueller’s probe of Russian meddling in the 2016 elections.
- Counsel conducting pre-merger FCPA compliance audit of international medical device manufacturer.
- Representation of business owner criminally charged with violation of OFAC regulations relating to Iran Sanctions.
- Representation of former senior official of FIFA in a wide-ranging bribery investigation of FIFA by the DOJ.
- Representation of individual in Foreign Agents Registration Act (FARA) criminal investigation and prosecution.
- Counsel performing independent review of anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance program in place at international, publicly traded casino.
- Representation of consulting firm in responding to letter for inquiry from the Foreign Agents Registration (FARA) Unit of DOJ.
- Counsel conducting FCPA audit and analysis on behalf of multinational agricultural company.
- Representation of various senior government officials in investigations by DOJ and OIG.
- Representation of Fortune 50 firm in internal investigations regarding compliance with FCPA.
- Counsel advising international commodity trading company regarding compliance with multiple OFAC sanctions regimes.
- Representation of European insurance executive in connection with criminal prosecution of international fraud scheme.
- Counsel to U.S. subsidiary regarding ITAR compliance relating to information accessible to foreign parent company.
- Counsel conducting review of compliance program for Fortune 50 firm.
- Representation of senior employee of large international oil-sector business in connection with DOJ investigation of potential violations of OFAC regulations relating to Iran Sanctions.
- Counsel to foreign purchaser of U.S. telecommunications company in connection with CFIUS review.
- Counsel to domestic energy company during CFIUS review of company’s sale of assets to a foreign buyer.
- Counsel to numerous U.S. businesses on compliance with ITAR, EAR and OFAC regulations in connection with international operations.
- Representation of individuals and an organization in several criminal investigations of potential violations of Federal election laws prohibiting conduit contributions.
- Representation of healthcare executive in connection with investigation of kickbacks and false claims.
- Counsel to domestic manufacturer of defense systems during CFIUS review of its acquisition by a European company.
Events
- Speaker, "Russia Sanctions and the Unique Challenges for Global Life Science Companies," American Conference Institute’s Annual FCPA & Anti-Corruption for the Life Sciences Industry Forum, May 11, 2023
- Speaker, "Economic Sanctions, FCPA and the Impact on Distributor and More Third-Party Relationships: Leveraging Screening and Compliance Resources to Reduce DOJ, SEC and OFAC Penalty Risks," American Conference Institute’s Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, July 22, 2022
- Panelist, Government Regulatory and Enforcement Outlook 2022, March 16 & 17, 2022
- Speaker, "Global Anti-Corruption and Economic Sanctions," American Conference Institute’s 13th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, June 19, 2019
- Speaker, "FCPA and Economic Sanctions," American Conference Institute’s 13th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, April 28, 2016
- Speaker, "Heading Outbound: the Do’s, Don’ts and Insight into the Latest Trends," Fourth Annual U.S.-China Legal Summit, February 25, 2016
- Moderator, "Foreign Corrupt Practices Act," 7th Annual Medical Device and Life Sciences Conference, November 19, 2015
- Speaker, "Can You Be Commercial and Compliant?," FCPA Transactional Diligence:Can You Be Commercial and Compliant?, Complimentary Live Program, December 3, 2014
- Moderator, "Foreign Corrupt Practices Act," 6th Annual Medical Device and Life Sciences Conference, November 18, 2014
- Speaker, "Responding to Increased False Claims Act Enforcement," Healthcare and Life Sciences Litigation, April 24, 2012
- Speaker, "The Prosecution of Professor Roth and Its Aftermath," The Export Practitioner Audio-Conference Briefing, November 15, 2011
- Panelist, "Are Your Global Business Partners Exposing You to FCPA Liability?," Merrill Brink International Panel Discussion, March 1, 2011
- Speaker, "Foreign Corrupt Practices Act: Ensuring Compliance and Avoiding the DOJ Target," Elsevier Business Intelligence Webinar, February 17, 2011
- Speaker, "False Claims Act Changes & Compliance Effectiveness," 2nd Annual Medical Device, Durable Medical Equipment & Diagnostics Conference, McGuireWoods LLP Seminar, November 2010
- Speaker, UK Bribery Act 2010, October 13, 2010
- Speaker, "ITAR Compliance at Universities after the Roth Case," American Bar Association, International Law Section, March 2, 2010
- Speaker, American Conference Institute’s 5th National Forum on Export Enforcement & Investigations, January 28, 2010
- Speaker, "Export Controls Prosecution after Pulungan," The Export Practitioner Audio-Conference Briefing, September 15, 2009
- Speaker, American Bar Association 4th Annual Homeland Security Law Institute, February 26, 2009
- Speaker, American Conference Institute’s 4th National Forum on Export Enforcement & Investigations, January 29, 2009
- Witness, Testimony Regarding Enforcement of Federal Espionage Laws, January 29, 2008
- Witness, "The USA PATRIOT ACT: Dispelling the Myths," Subcommittee on Crime, Terrorism, and Homeland Security, Committee on the Judiciary, U.S. House of Representatives, May 11, 2001
Insights
- Co-author, "Analysing the impact of sanctions and export controls on supply chains," Global Investigations Review, The Guide to Sanctions - Sixth Edition, 2025
- Author, After a Pause, DOJ’s Updated FCPA Guidelines Focus on Cartels and TCOs, But Corporate Exposure Remains, Subject to Inquiry, June 30, 2025
- Author, Trump Tariffs on Canada, Mexico, and China, Subject to Inquiry, February 4, 2025
- Author, OFAC Enforcement Action Targets Non-U.S. Business Purchasing Services From North Korean Firm, Subject to Inquiry, July 1, 2024
- Author, Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary Self-Disclosure Program, Subject to Inquiry, June 5, 2024
- Author, Disruptive Technology Strike Force Continues Focus on Trade Secret Theft, Export Control Enforcement, McGuireWoods Legal Alert, February 15, 2024
- Author, Recent Sanctions Enforcement Actions Demonstrate Importance of Incorporating All Available Data into Screening, Subject to Inquiry, January 31, 2024
- Co-author, Impacts of Sanctions and Export Controls on Supply Chains, Global Investigations Review, The Guide to Sanctions: Fourth Edition, September 29, 2023
- Author, "Strike Force Actions Underscore Foreign Risks For Tech Cos.," Law360, August 10, 2023
- Author, Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations, Subject to Inquiry, July 31, 2023
- Author, Disruptive Technology Strike Force Initiates Federal Prosecutions Targeting Trade Secret Theft, McGuireWoods Legal Alert, June 27, 2023
- Author, U.S. DOJ and Partners Increasing Enforcement of Sanctions and Export Controls, Subject to Inquiry, March 6, 2023
- Author, FinCEN Alert Highlights Potential U.S. Real Estate Investments by Sanctioned Russian Elites, Consumer FinSights, January 30, 2023
- Co-author, "Impacts of Sanctions and Export Controls on Supply Chains," Global Investigations Review, The Guide to Sanctions: Third Edition, June 2022
- Author, Less Is More? DOJ Signals Shift to More Targeted Evidence Collection, Subject to Inquiry, June 27, 2022
- Author, New Revelations in Ukraine Lead to Tightening Global Sanctions, Subject to Inquiry, April 8, 2022
- Author, Western Companies Starting to Feel Impact of Russian Sanctions, Subject to Inquiry, March 24, 2022
- Author, DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion, Subject to Inquiry, March 9, 2022
- Author, U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus, Subject to Inquiry, February 28, 2022
- Author, Additional Sanctions on Russia and the Importance of Business Contingency Planning, Subject to Inquiry, February 23, 2022
- Author, Biden Administration Issues Initial Ukraine Sanctions, Subject to Inquiry, February 22, 2022
- Author, What Significant Russian Sanctions Could Look Like and How to Prepare, Subject to Inquiry, January 18, 2022
- Author, Perils of Global Expansion: Ad Agency Fined $19 Million for FCPA Violations, Insufficient Controls, Subject to Inquiry, October 25, 2021
- Author, Sanctions and Export Compliance Strategies for Supply Chains, Subject to Inquiry, August 12, 2021
- Contributor, "Part III: Sanctions in Practice – Impacts of Sanctions and Export Controls on Supply Chains," Global Investigations Review's The Guide to Sanctions: Second Edition, July 13, 2021
- Author, The Perils of Pleading the Fifth in the Corporate Fraud Context, Subject to Inquiry, April 27, 2021
- Author, NSCAI Recommends $40 Billion Investment in Artificial Intelligence, R&D and Innovation, McGuireWoods Legal Alert, April 15, 2021
- Author, Biden Administration Orders Comprehensive Review of U.S. Supply Chain, McGuireWoods Legal Alert, March 1, 2021
- Author, FinCEN Comments on New Guidance for Section 314(b) Information-Sharing Program, Subject to Inquiry, December 30, 2020
- Author, 3rd Circuit Case of First Impression Clarifies Lower Threshold for FCA Actions, McGuireWoods Legal Alert, March 6, 2020
- Author, What the Venezuela Sanctions May Mean for Future Sanctions Programs, Subject to Inquiry, March 11, 2019
- Author, Congressional Investigations: Beyond Sensational Headlines — Incoming House Leaders Announce Broad Investigative Priorities Targeting Business Community, McGuireWoods Legal Alert, December 19, 2018
- Author, 2nd Circuit Clarifies Limits of FCPA’s Extraterritorial Reach, Subject to Inquiry, September 7, 2018
- Author, FinCEN Opens 2017 with SAR Sharing Guidance for Casinos, Subject to Inquiry, January 9, 2017
- Author, New Rules for Cleared Contractors Starting Nov. 30, McGuireWoods Legal Alert, November 29, 2016
- Author, FinCEN Associate Director for Enforcement Delivers Remarks at Title 31 Conference, Stresses Importance of Culture of Compliance, Subject to Inquiry, September 21, 2016
- Author, DOJ’s First Corporate Enforcement Action Under FCPA Pilot Program, Subject to Inquiry, July 5, 2016
- Author, The Export/Immigration Dilemma: Don’t Let OSC Catch Your HR Department Unaware, McGuireWoods Legal Alert, May 5, 2016
- Author, Casino AML: FinCEN Fines Former Sparks Nugget Management $1 Million, Subject to Inquiry, April 7, 2016
- Author, Iran Sanctions and the Implementation of the JCPOA: Lots of Changes, but Little Impact on U.S. Businesses?, McGuireWoods Legal Alert, January 20, 2016
- Author, FinCEN Announces First Card Club AML Enforcement Action, Subject to Inquiry, January 11, 2016
- Author, A New FCPA Policy May Be Coming, but Questions Remain, McGuireWoods Legal Alert, November 13, 2015
- Co-author, "FinCEN’s Caesars Penalty A Cautionary Tale For Casinos," Law360, September 17, 2015
- Author, FinCEN Announces Caesars Penalty After Multiyear Investigation, Subject to Inquiry, September 11, 2015
- Co-author, "Compliance Concerns Complicate Credit Agreements," Just Anti-Corruption, September 4, 2015
- Author, FinCEN Final Rule on Foreign Bank Requires Covered Financial Institutions to Take “Special Measures”, Subject to Inquiry, August 11, 2015
- Co-author, "Tinian Dynasty Case Provides A Few Reminders For Casinos," Law360, August 10, 2015
- Author, Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty, Subject to Inquiry, July 31, 2015
- Author, White House Hostage Policy Leaves Risk on Table for Third Parties, Subject to Inquiry, July 28, 2015
- Author, Still Certain about Uncertainty − Waiting on the Details in the New Iran Nuclear Deal, McGuireWoods Legal Alert, July 15, 2015
- Author, AML Compliance Developments in the Gaming Industry, Subject to Inquiry, April 28, 2015
- Author, Latest US Sanctions Against Russia Target Financial Services and Energy Sector, Subject to Inquiry, July 17, 2014
- Author, Not Every Payment to a Foreign Official is a Bribe, Subject to Inquiry, May 20, 2014
- Co-author, "ITAR Violations: Mistake Or Willful Act?," Law 360, May 6, 2014
- Author, U.S. Department of Treasury Adopts New Sanctions Against Russia, McGuireWoods Legal Alert, May 1, 2014
- Author, Violations of the ITAR, EAR or OFAC Regulations: Mistake or Willful Act?, Subject to Inquiry, April 22, 2014
- Author, EU, U.S. Slap Sanctions on Russian and Ukrainian Officials, McGuireWoods Legal Alert, March 18, 2014
- Co-author, "Food And Beverage Industry Outlook For 2014: Part 2," Law360, January 23, 2014
- Author, 2014 Food Industry Outlook, McGuireWoods Legal Alert, January 8, 2014
- Author, Defamation Claims Increase Costs of Cooperation with Government Investigations, Subject to Inquiry, July 12, 2013
- Author, As Companies Wind Down in Iran, the President Must Roll Up his Investigative Sleeves, Subject to Inquiry, April 1, 2013
- Author, SEC Adopts Final Rule on Conflict Minerals Disclosure Requirements, McGuireWoods Legal Alert, August 24, 2012
- Author, SEC Sets Vote in August on “Conflict Minerals” Disclosure Rules, McGuireWoods Legal Alert, July 11, 2012
- Author, Offshore Outsourcing – The Convergence of Immigration, Labor and Tax Issues, McGuireWoods Legal Alert, May 8, 2012
- Author, Government Scrutiny Underscores Potential Risks for U.S. Companies With Offshore Service or Tech Operations, McGuireWoods Legal Alert, February 9, 2012
- Author, 60-Day Suspension: Form I-129 (Petition for a Nonimmigrant Worker) Export Certification, McGuireWoods Legal Alert, December 23, 2010
- Author, H-1B and L-1 Employers Must Certify Compliance with U.S. Export Control Laws, McGuireWoods Legal Alert, December 22, 2010
- Co-author, Taking Your Medicine, Washington Legal Foundation, November 2010
- Author, Size Doesn’t Matter: SEC Targets Small, Newly Formed Public Companies in their Crusade Against Corruption, McGuireWoods Legal Alert, July 9, 2010
- Author, New UK Bribery Act 2010: Are You Compliant?, McGuireWoods Legal Alert, May 18, 2010
- Author, Enhanced Anticorruption Enforcement on Track in UK Parliament, McGuireWoods Legal Alert, March 4, 2010
- Author, Charm Offensive: Three Top DOJ, SEC Officials Describe “New Chapter” in FCPA, Other White Collar Criminal Enforcement, McGuireWoods Legal Alert, March 1, 2010
- Author, "Catch-22: Deconstructing FCPA Sting of Arms Exporters," The Export Practitioner, February 2010
- Author, "Conviction of Professor Roth Will Increase Focus on U.S. Labs," The Export Practitioner, August 2009
- Selected for inclusion in The Best Lawyers In America, Criminal Defense: White Collar, 2023-2026
- Named a “Local Litigation Star,” Benchmark Litigation, 2018
- Selected for inclusion as a “Leading Lawyer,” Corporate Investigations And White-Collar Criminal Defense, Washington, D.C., Legal 500 US, 2017
- Recipient, Director’s Award for Superior Performance as Assistant U.S. Attorney, Executive Office of U.S. Attorneys, 2005
- Senior Litigation Counsel, U.S. Attorney’s Office for the District of Columbia, 2001