Overview
Warren Geary represents companies confronting complex regulatory, enforcement, and commercial issues in highly regulated and national security-sensitive sectors. His practice spans economic sanctions, export controls, government contracts, internal investigations, and related litigation.
Warren frequently counsels clients on a broad range of sanctions and export controls issues, including licensing, compliance program development, internal investigations, voluntary self-disclosures, enforcement matters, and efforts to secure removal from US government restricted-party lists. He regularly assists clients with matters involving the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).
Complementing his trade practice, Warren brings the same national security and regulatory risk perspective to counseling government contractors and other organizations on procurement and compliance issues, including small business counseling and set-aside compliance. His experience includes bid protests, False Claims Act and qui tam investigations and litigation, internal investigations, industrial security matters, and other disputes arising from government contracts and grants. He works with clients to manage regulatory risk, respond to government inquiries, and address challenges that arise at every stage of the contracting process. Warren also assists clients in complex commercial and international arbitration proceedings.
Before entering private practice, Warren served as an active-duty officer in the US Army, leading teams and managing mission-critical procurement and logistics operations across the United States, the Middle East, and the Indo-Pacific region. Drawing on that experience, he brings a practical understanding of the regulatory, operational, and national security considerations that shape his clients' most significant challenges. He continues to serve in the US Army Reserve.
- Texas
- District of Columbia
- J.D., Georgetown University Law Center
- B.S., United States Military Academy at West Point
Areas of Work
Representative Matters
- Represented a private equity fund and several of its portfolio companies in investigating multiple False Claims Act violations and voluntarily disclosing the issues to the government leading to no enforcement action.
- Advised a client on structuring a small business to bid on Department of Defense contracts.
- Represented a client in investigating and disclosing potential sanctions violations related to mobile banking transactions, resulting in the matter closing without enforcement action.
- Advised on Defective Pricing under the Truth in Negotiations Act (TINA) and International Traffic in Arms Regulations (ITAR) compliance matters as part of a monitorship for a defense industry manufacturer.
- Advised a client on negotiating a Special Security Agreement (SSA) with the Defense Counterintelligence and Security Agency (DCSA).
- Advised a subcontractor on Foreign Military Sales negotiations and compliance obligations with a prime contractor, including restructuring its overseas entities to meet local requirements.