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


April 10, 2018

FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements

Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new Customer Due Diligence Rule (CDD Rule), set to go into effect on May 11, 2018. This client alert was also published by New York University School of Law's Compliance & Enforcement Blog.

January 11, 2018

WilmerHale Represents US Currency Paper Manufacturer Crane & Co., Inc. in $800 Million Sale

On December 5, 2017, Crane & Co., Inc., the manufacturer of currency paper for the US government since 1802, signed an agreement to be acquired by Crane Co. (NYSE: CR), a diversified manufacturer of highly engineered industrial products (and unrelated to the target company), for $800 million on a cash free and debt free basis.

December 22, 2017

Global Magnitsky Sanctions Target Human Rights Abusers and Government Corruption Around the World

This article also appeared on the New York University School of Law Compliance and Enforcement Blog.

December 19, 2017

FinCEN Launches New Information-Sharing Platform: The FinCEN Exchange

Treasury's Financial Crimes Enforcement Network recently announced the creation of the FinCEN Exchange, a new voluntary platform to facilitate information sharing between the government and industry on topics related to anti–money laundering and other financial crime issues.

November 16, 2017

The US Revises Commercial and Travel Sanctions Against Cuba

The US Departments of the Treasury and Commerce implemented President Trump's June 2017 National Security Presidential Memorandum that was designed to tighten restrictions on individual travel to Cuba and on dealings with Cuban military-related entities.

November 15, 2017

David Cohen Named to Advisory Board of National Security Institute, George Mason University Antonin Scalia Law School

The NSI describes itself as “a platform for research, teaching, scholarship, and policy development” related to the security threats facing the US and its allies.

October 27, 2017

WilmerHale Ranks No. 1 on Global Investigations Review's List of Top Investigations Practices

WilmerHale has climbed to the top of Global Investigations Review's list of the world's 30 leading investigations and compliance practices.

September 26, 2017

Trump Administration Imposes Broad New Sanctions Against North Korea

Over the past several years, as North Korea has increased the capability of its nuclear and ballistic missile program, there has been a steady increase in sanctions pressure against North Korea by the United States and the broader international community. In response to the latest provocations from North Korea, late last week President Trump declared that it was time to “maximize pressure” on North Korea and signed a new Executive Order.

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.

Professional Activities

Mr. Cohen is an advisory board member of the National Security Institute at George Mason University's Antonin Scalia Law School and is on the Board of Trustees at Cornell University.