Gary Klubok
Associate
Overview
Gary Klubok is a Washington, D.C., and Miami lawyer and member of Holland & Knight's White Collar Defense and Investigations Team and Consumer Protection Defense and Compliance Team.
White Collar Defense and Investigations
As a Certified Fraud Examiner (CFE) and Certified Anti-Money Laundering Specialist (CAMS), Mr. Klubok assists clients with matters involving fraud, money laundering, corruption, bribery, compliance, Foreign Corrupt Practices Act (FCPA), extradition and forfeiture matters, in addition to representing financial institutions in Bank Secrecy Act (BSA) and USA Patriot Act anti-money laundering (AML) matters. Mr. Klubok has represented clients around the world on matters before the U.S. Department of Justice (DOJ) and U.S. Department of the Treasury, including the Financial Crimes Enforcement Network (FinCEN). His longstanding interest in white collar and investigative work dates back to law school, where he earned the top grade and CALI Excellence for the Future Award in International Anti-Corruption Law.
Regulatory Compliance and Enforcement Actions
Mr. Klubok advises banks, financial institutions and companies on navigating complex regulatory frameworks and enforcement actions involving consumer services. He counsels clients on strengthening their corporate compliance programs, including developing policies and procedures to reduce legal and regulatory risk. Mr. Klubok has experience advising on a range of federal and state consumer protection laws, including the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Consumer Protection Act and Federal Trade Commission Act (FTCA). He also counsels companies on structuring sweepstakes and contests to ensure legal compliance and minimize legal risks. In addition, as a U.S. Certified Information Privacy Professional (CIPP/US), Mr. Klubok advises clients on cyber-related inquiries involving regulators such as the Federal Trade Commission (FTC).
Community Involvement
Mr. Klubok is heavily involved in the community. He founded and leads the nonprofit organization Homeless Helpers, which gives supplies and food directly to the homeless in Virginia and Washington, D.C. He also maintains an active pro bono practice. Mr. Klubok is a pro bono attorney with Florida's Guardian ad Litem office, where he helps to represent abused, abandoned or neglected children in Miami-Dade County courts. In addition, Mr. Klubok has provided pro bono assistance to asylum seekers, particularly Spanish-speaking clients, and parents in Hague Convention child abduction proceedings. One client in a Hague Convention matter thanked Mr. Klubok for Holland & Knight's "wonderful humanitarian gesture" for helping to return the client's child home after 15 months. Since beginning his legal career, Mr. Klubok has contributed more than 100 hours of pro bono service annually.
Mr. Klubok volunteered as a big brother in Big Brothers Big Sisters of the National Capital Area from 2024 to 2025. An avid animal advocate, he donates monthly to the American Society for the Prevention of Cruelty to Animals (ASPCA) and the Humane Society of the United States. He has served multiple times as a judge for the "Do the Write Thing" writing competition, part of the National Campaign to Stop Violence. Each holiday season, Mr. Klubok purchases toys for foster children through Bunchy's Toy Drive in Miami.
While in law school, Mr. Klubok was selected to intern for the Honorable John D. Couriel of the Florida Supreme Court as part of the court's Internship Program for Distinguished Florida Law Students. He also interned for the Honorable Jose E. Martinez of the U.S. District Court for the Southern District of Florida.
Media Coverage
- Law360, "Competing Miami Christmas Event Can Go On, Court Says," November 28, 2023
- Law.com, "Holland & Knight Prevails in Round 1 of Holiday Lawsuit Brought by 'Santa'," November 13, 2023
- Law360, "Bank Scheme Ruling Spotlights Clash Over Limits of Fraud," November 3, 2021
Representative Experience
- Represented a global, private company in a U.S. Department of Justice (DOJ) investigation into alleged violations of the Foreign Corrupt Practices Act (FCPA)
- Advised a bank before the Financial Crimes Enforcement Network (FinCEN) and DOJ regarding allegations of violating suspicious activity reporting (SARs) and currency transaction reporting (CTRs) requirements under the Bank Secrecy Act (BSA)
- Represented a bank in a DOJ investigation concerning alleged violations of the Financial Institutions Reform, Recovery and Enforcement Act (FIRREA)
- Advised a bank before the DOJ related to public bribery and fraud
- Represented a business executive in a DOJ investigation involving alleged wire fraud, conspiracy to defraud the U.S. and violations of the Racketeer Influenced and Corrupt Organizations Act (RICO)
- Advised a private businessperson before the DOJ regarding allegations of violating the FCPA
- Advised a financial institution before Puerto Rico's Office of the Commissioner of Financial Institutions (OCIF) regarding allegations of violations of the BSA for failing to maintain and implement an anti-money laundering program
- Advised an individual before the DOJ related to private bribery and bid rigging
- Advised a company before the DOJ related to transporting large amounts of currency under the BSA
- Advised a bank regarding an internal investigation into alleged breaches of fiduciary duties by an executive
- Advised the board of directors of a Fortune 500 company regarding training on compliance with the FCPA
- Advised a company before the Federal Trade Commission (FTC) regarding data breaches and whether the company’s cyber practices were deceptive
- Advised a company before the FTC regarding whether its solicitations violated the Federal Trade Commission Act (FTCA) and Unordered Merchandise Statute
- Counseled a financial institution on whether a proposed product would be classified as a consumer reporting agency under the Fair Credit Reporting Act (FCRA)
- Participated in a comprehensive, multistate project identifying and analyzing all state laws applicable to the operations and services of a large national bank
- Advised a foreign retail company on structuring a legally compliant social media sweepstakes
- Helped design a regulatory database for a major national bank to track and manage compliance obligations across its financial operations
- Provided legal guidance to an investment firm on the classification of a new loan product under relevant federal and state laws
- Advised a company on whether specific business practices potentially violated the Fair Debt Collection Practices Act (FDCPA)
- Assisted a golf-equipment brand and an education platform in structuring and launching compliant sweepstakes promotions
- Defeated an emergency, preliminary injunction seeking to shut down a client's holiday festival weeks before opening
- Won a motion for a temporary restraining order reinstating company directors wrongly removed from the board of directors
- Won a motion for judgment on the pleadings, receiving dismissal of a multimillion-dollar negligence lawsuit
- Represented a Brazilian company in a lawsuit related to commercial fraud from a bribery scheme
- Represented a Brazilian company in a lawsuit related to intellectual property (IP) on a global e-commerce website
- Represented a parent who alleged under the Hague Convention that his child was improperly kept in the U.S.
Credentials
- University of Miami School of Law, J.D., magna cum laude
- John Jay College of Criminal Justice, M.S., Protection Management, emphasis in Emergency Management
- John Jay College of Criminal Justice, B.S., Security Management, with honors
- District of Columbia
- Florida
- Certified E-Discovery Specialist (CEDS), Association of Certified E-Discovery Specialists (ACEDS)
- Certified Fraud Examiner (CFE), Association of Certified Fraud Examiners (ACFE)
- Certified Information Privacy Professional/United States (CIPP/US), International Association of Privacy Professionals (IAPP)
- Certified Anti-Money Laundering Specialist (CAMS), Association of Certified Anti-Money Laundering Professionals (ACAMS)
- American Society for the Prevention of Cruelty to Animals (ASPCA)
- Humane Society of the United States
- CALI Excellence for the Future Award, International Anti-Corruption Law and Practice, University of Miami School of Law
- CALI Excellence for the Future Award, Legal Communication and Research II, University of Miami School of Law
- Dean's Certificate of Achievement Award in Civil Procedure I, University of Miami Law School of Law
- English