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Michael S. Dry
Michael S. Dry
Partner — Government Investigations & White Collar Criminal Defense
Partner — Government Investigations & White Collar Criminal Defense

Michael S. Dry

Michael S. Dry
Washington

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037

start quote symbolIn what I do, there are clear winners and clear losers. I’m often entrusted with preserving someone’s freedom or a company’s very existence, so I’m committed to moving the chess pieces around so that my clients are on the winning side.end quote symbol
Michael S. Dry

Defense attorney Michael Dry represents companies and individuals facing serious legal issues, including allegations of domestic and international criminal and civil violations as well as complex civil litigation. He has defended clients against allegations of bribery under the Foreign Corrupt Practices Act, securities fraud and insider trading, among other charges, and also regularly advises clients on managing cybersecurity risks and economic sanctions. As his clients weather challenging times, Michael counsels them on crisis management, providing guidance on internal investigations, whistleblower issues, shareholder lawsuits and reputational concerns.

The former Deputy Criminal Chief for the Eastern District of Virginia, Michael draws on his decade-plus experience as a federal prosecutor to formulate deft legal strategies to address investigations by the Department of Justice, the Securities and Exchange Commission, the Financial Industry Regulatory Authority and other enforcement authorities. He has a strong track record of convincing authorities to close their investigations without taking action against his clients, avoiding costly courtroom battles and negative press. When clients do attract reporters’ attention, Michael advises on their engagement with the press to minimize damaging coverage. And when it is necessary to go to trial, Mike skillfully distills complex issues and legal theories in terms juries and judges can understand. Mike’s cross examinations have been described as “pointed and methodical” by the New York Times (2014) and “especially dramatic” by the Washington Post (2014).

Michael also has extensive experience managing matters involving regulators and authorities abroad, including those in Europe, the Middle East and Asia. He is skilled at working with lawyers around the world and coordinating defense strategies to ensure consistency across multiple jurisdictions.

Experience Highlights

  • Represented a Fortune 500 company in both criminal and Congressional investigations involving allegations of securities fraud.

  • Represented publicly traded company in criminal investigations by the Department of Justice and foreign regulators involving allegations of Foreign Corrupt Practices Act violations.

  • Defended multi-billion dollar defense contractor in related Department of Justice criminal and False Claims Act investigations resulting in criminal declination and favorable no-admit, no-deny civil settlement 

  • Represented senior FIFA executive during criminal investigation by the U.S. Attorney’s Office for the Eastern District of New York resulting in declination

  • (E.D. Va.) — Led multi-agency investigation and prosecution of Costa Rican reinsurance company, its CEO, and CFO for the sale of more than $500 million of fraudulent financial guarantee bonds to over 3,500 investors worldwide; coordinated parallel investigations with SEC and foreign law enforcement partners and negotiated plea agreements with both the corporation and the CFO; served as co-lead trial counsel at CEO’s jury trial, where he was convicted on all counts

  • (E.D. Va.) — Led investigation and prosecution of six hedge fund executives for their involvement in the sale of more than $100 million of fraudulent securities to more than 800 investors nationwide; coordinated parallel investigations by the SEC and numerous state securities regulators; served as lead trial counsel for the separate multi-week jury trials of the two hedge fund managers, which resulted in convictions on all counts

  • Led investigation of publicly traded South Korean chemical company and its executives for their attempted theft of trade secrets and negotiated deferred prosecution agreement that included a multi-million dollar criminal penalty

  • (E.D. Va.) — Led investigation and prosecution of senior executives of national tax-deferred exchange company for their involvement in the misappropriation of more than $130 million of client exchange funds; served as lead trial counsel for the multi-week jury trial of the CEO, which resulted in convictions on all counts and a sentence of 100 years imprisonment

  • Led investigation and prosecution of the Vice President of a U.S. maritime company on FCPA charges; defendant pleaded guilty and was sentenced to 87 months imprisonment, which at the time was the longest FCPA sentence in U.S. history

  • Supervised investigation of major casino for suspected money laundering crimes related to violations of applicable Know Your Customer, Currency Transaction Report, and Suspicious Activity Report regulations  

  • Supervised several cyber intrusion investigations involving major companies from a myriad of industries and oversaw coordination between victim companies, civilian regulators, and law enforcement

  • Negotiated a plea agreement with a New York Stock Exchange-traded company to Clean Water Act violations that included a multi-million dollar criminal fine, a compliance program, and a multi-million dollar restoration project for the Chesapeake Bay

  • Secured a guilty plea from the president of a commodities trading firm for $9 million fraud; the investigation was complete within six weeks

  • Negotiated a non-prosecution agreement with one of the largest global construction firms that included a third-party nationwide environmental audit, a new environmental compliance program, and a criminal fine

  • (Va. Cir.) — Represented a Fortune 100 defense contractor in jury trial on wrongful death lawsuit brought by family of deceased U.S. Navy sailor (second chair)

Credentials

  • College of William & Mary, J.D., 2002 (Order of the Coif)
  • University of Nebraska, M.B.A., 1997
  • University of Louisville, B.S., 1990
  • Deputy Criminal Chief, U.S. Attorney’s Office for the Eastern District of Virginia, 2012-2016
  • Senior Litigation Counsel, U.S. Attorney’s Office for the Eastern District of Virginia, 2011-2012
  • Corporate & Securities Fraud Coordinator, U.S. Attorney’s Office for the Eastern District of Virginia, 2010-2011
  • Assistant United States Attorney, U.S. Attorney’s Office for the Eastern District of Virginia, 2004-2016
  • Associate, Hunton & Williams LLP, 2003-2004
  • Judicial clerk to The Honorable Robert G. Doumar, U.S. District Court for the Eastern District of Virginia, 2002-2003
  • Captain, Chief Standardization and Evaluation Navigator, United States Air Force, Air Combat Command, 1991-1999
  • Chambers USA, Litigation: White-Collar Crime & Government Investigations (District of Columbia), 2020
  • The Best Lawyers in America© (BL Rankings, LLC), 2021
  • Member: Fourth Circuit Judicial Conference
  • Member: Federal Bar Association
  • Faculty Member: American Bar Association Annual Securities Fraud Institute, 2007-Present
  • Faculty Member, Lecturer, and Criminal Trial Advocacy Instructor: U.S. Department of Justice National Advocacy Center, 2011-2016
  • Virginia
  • District of Columbia
  • Eastern District of Virginia
  • United States Court of Appeals for the Fourth Circuit
  • “Preparing for and Managing Risks Involved with Cross-Border Investigations,” V&E Houston Office, September 20, 2018 (panelist)
  • “Trade Secrets Protection and Litigation: How to Respond Effectively When A Company Becomes A Victim of Intellectual Property Theft,” June 15, 2017 (speaker)
  • “Responding to the Inevitable: Common Mistakes in Cyberattack Planning and Responses,” V&E Cybersecurity and Data Privacy Insights E-communication, June 14, 2017 (co-author)
  • “Counsel as Quarterback During Data Breaches,” Incident Response Forum 2016, March 31, 2016 (co-panelist)
  • “The Governor McDonnell Case – Where Do We Go From Here in Public Corruption,” 31st Annual National Institute on White Collar Crime, March 8-10, 2016 (panelist)
  • “Cybersecurity and Disclosure Obligations,” Ninth Annual National Institute on Securities Fraud, American Bar Association, November 2014 (panelist)
  • “The Financial Crisis: Intersection of Mortgage-Backed Securities & Fraud,” Seventh Annual National Institute on Securities Fraud, American Bar Association, October 2012 (panelist)
  • “Insider Trading Knows No Bounds: What Theory Will They Come Up With Next?,” Fourth Annual National Institute on Securities Fraud, American Bar Association, October 2009 (co-panelist)
  • “Strategies for Creating Multi-Agency Financial Fraud Task Forces,” U.S. Department of Justice National Advocacy Center, May 2009 (speaker)
  • “Investigative Strategies for Corporate Targets,” U.S. Department of Justice National Procurement Fraud Conference, 2008 (speaker)
  • “Regulation Overload or Striking the Right Balance?,” Second Annual National Institute on Securities Fraud, American Bar Association, October 2007 (co-panelist)