David S. Cohen


Cohen, David

David Cohen provides clients with anti-money laundering, financial and trade sanctions advice; represents US and foreign-based clients in matters implicating national security, including CFIUS and cybersecurity; conducts internal investigations; and defends clients facing government investigations. His practice has a strong emphasis on disputes involving US and foreign regulators and enforcement agencies, often involving cross-border issues, as well as proceedings in US and foreign adjudicative venues.

Before rejoining the firm in 2017, Mr. Cohen served for eight years in senior presidentially appointed positions. From 2015–2017, Mr. Cohen was Deputy Director of the Central Intelligence Agency (CIA), where he helped manage the Agency's domestic and worldwide operations, oversee its strategic modernization, and lead foreign intelligence collection, all-source analysis, covert action, counter-intelligence and foreign liaison relationships. Mr. Cohen also directed special projects on the impact of new technologies on the Agency and on how best to work with US companies to advance the CIA's mission. At the conclusion of his tenure, Mr. Cohen was awarded the Distinguished Intelligence Medal, the CIA's highest honor.

Previously, Mr. Cohen served for four years in the US Department of the Treasury as Under Secretary for Terrorism and Financial Intelligence, where he managed the department's policy, regulatory, enforcement and intelligence functions aimed at combating illicit finance, including money laundering and other financial crime, and disrupting financial support to nations, organizations and individuals posing a threat to national security. He directly supervised the Office of Foreign Assets Control (OFAC), which implements financial and economic sanctions, and the Financial Crimes Enforcement Network (FinCEN), the anti-money laundering regulatory and enforcement agency. Mr. Cohen was instrumental in developing and implementing sanctions against Iran, Russia, North Korea, ISIS, al Qa'ida and other terrorist organizations, for which he was described as “President Obama's favorite combatant commander” and as the administration's “financial Batman.”

Mr. Cohen previously served for two years as Assistant Secretary of the Treasury for Terrorist Financing, overseeing policy development related to sanctions and money laundering. Earlier in his career, Mr. Cohen served in Treasury's general counsel's office, where he helped craft legislation that formed the basis of Title III of the USA PATRIOT Act, the post-9/11 legislation that provided new tools to prevent money laundering and the financing of terrorism.

Prior to his most recent government service, Mr. Cohen practiced law in Washington DC for nearly 20 years, including as a partner at WilmerHale. His practice at WilmerHale focused on complex civil litigation, white-collar criminal defense, internal investigations, and anti-money laundering and sanctions compliance advice.

Publications & News


September 22, 2017

David Cohen Explains How US North Korea Sanctions Pressure Chinese Banks on PBS NewsHour

Following the Trump Administration's announcement of increased economic sanctions on North Korea on September 21, Partner David Cohen explained on PBS NewsHour that the move placed particular pressure on Chinese financial institutions.

September 15, 2017

David Cohen Discusses Growing Importance and Complexity of Sanctions on C-SPAN

Partner David Cohen, former deputy director of the Central Intelligence Agency who also served as Under Secretary of the Treasury for Terrorism and Financial Intelligence, fielded questions about the use of financial and economic sanctions against Russia, North Korea and Venezuela during a recent discussion at Georgetown University Law Center.

September 7, 2017

David S. Cohen, Former CIA Deputy Director and Treasury Under Secretary, Rejoins WilmerHale

WilmerHale is pleased to announce that David S. Cohen, former Deputy Director of the Central Intelligence Agency and Under Secretary of the Treasury for Terrorism and Financial Intelligence, has returned to the firm as a partner.

November 10, 2008

OFAC Issues Compliance Guidance for Securities Industry

On Nov. 5, 2008, the US Treasury Department's Office of Foreign Assets Control (OFAC) issued new guidance for the securities industry, "Opening Securities and Futures Accounts from an OFAC Perspective," and revised existing guidance, "Risk Factors for OFAC Compliance in the Securities Industry."

March 1, 2006

FinCEN Issues Anti-Money Laundering Rules on Foreign Correspondent and Private Banking Accounts: Substantial Due Diligence Mandated for Banks, Broker-Dealers, Mutual Funds, Others

Financial Institutions and Securities Briefing Series

February 1, 2006

Anti-Money Laundering Rules for Insurance Companies Contain New Twists

An article by David Cohen, Stephen Heifetz and Emily Westerberg Russell published in the February 2006 issue of the Privacy & Data Security Law Journal.

December 9, 2005

Financial Institutions Law Update

Anti-Money Laundering Rules for Insurance Companies Contain New Twists

January 14, 2004

Wilmer Names Eight New Partners

The Following Wilmer Attorneys were Elected to the Partnership, Effective January 1, 2004: Stephanie Avakian, David S. Cohen, Edward C. DuMont, Fraser L. Hunter, Jr., Ronald C. Machen, Bruce H. Newman, John A. Trenor, and Amy Kreiger Wigmore