David M. Horn


Horn, David M.

David Horn’s practice focuses on advising clients on US sanctions programs and US export control law, including the Export Administration Regulations, anti-boycott provisions, OFAC sanctions requirements and the International Traffic in Arms Regulations. In representing clients in a variety of industries, including aerospace, finance and information technology, Mr. Horn’s work has involved responding to federal agency enforcement actions, providing legislative and strategic advice, and assisting with licensing, product classifications and voluntary self-disclosures.

Additionally, Mr. Horn has significant experience with trade remedy litigation before the US Court of International Trade, US Department of Commerce and International Trade Commission.


Prior to joining WilmerHale, Mr. Horn worked for Global Financial Integrity, a nonprofit in Washington DC, where he researched and wrote on matters of international money laundering and taxation. Mr. Horn was also an intern in the Litigation Bureau of the New York State Office of the Attorney General. Additionally, Mr. Horn served on the communications staff for Senator Tom Daschle’s Senate re-election campaign.

In law school, Mr. Horn was topics editor of the Boston College Law Review, and was the winner of Boston College Law School’s Grimes Moot Court Competition. Mr. Horn also worked in the BC Defenders Clinic, where he represented indigent defendants in criminal matters in Suffolk County.

Honors & Awards

  • Selected as a "Rising Star" in the 2016 and 2017 editions of Washington DC Super Lawyers

Publications & News


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.

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.

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.

August 28, 2017

New Sanctions Prohibit US Firms From Wide Range of Dealings With Venezuelan Government and PdVSA

On August 24, the Trump Administration significantly expanded sanctions against the Government of Venezuela, including state-owned oil company Petroleos de Venezuela, S.A.

July 31, 2017

President Expected to Sign New Sanctions Bill to Constrain Presidential Authority While Expanding "Sanctions Toolkit" for Russia, Iran, and North Korea

On July 27, the US Senate passed the Countering America's Adversaries Through Sanctions Act, a comprehensive sanctions bill that expands US sanctions against three countries: Russia, Iran and North Korea.

June 20, 2017

President Trump Announces New Cuba Restrictions

Although US policy since 2014 has been to normalize US-Cuba relations and liberalize trade with Cuba, President Trump signaled a partial reversal of US policy in a speech in Miami and the issuance of a National Security Presidential Memorandum, focusing on new restrictions on individual travel to Cuba and on dealings with Cuban military-related entities.

June 8, 2017

Secondary Sanctions Against North Korea Place Global Financial Firms at Risk

An article written by David Horn and published by Bloomberg BNA's Banking Report warns that non-US based global financial institutions could face risks from secondary sanctions against North Korea and that the Trump Administration may impose.

April 27, 2017

AML and Sanctions: 2017 Trends and Developments

This report reviews recent trends and developments impacting financial institutions with respect to the U.S. Bank Secrecy Act/Anti-Money Laundering and economic sanctions regulatory landscape.

April 24, 2017

US Announces Review of Iran Nuclear Deal

On April 18, 2017, the State Department certified to Congress that Iran was in compliance with its obligations under the Joint Comprehensive Plan of Action between the United States, Iran, and the P5+1 nations.

February 6, 2017

Treasury Department Imposes New Sanctions Against Iran and Clarifies Russia Cyber Sanctions

Last week saw the first action by the Treasury Department's Office of Foreign Assets Control under the new administration, including two notable developments.

Recent Highlights

  • Successfully represented one of the world’s largest international shipping groups with respect to the application of sanctions imposed under ISA/CISADA
  • Assisted a major US government contractor in developing ITAR compliance policies and training programs required for the provision of logistics services to the US military
  • Litigated on behalf of a coalition of the US plastics industry before the US Department of Commerce, International Trade Commission, and US Court of International Trade concerning dumped and subsidized imports from China, Taiwan and Brazil


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JD, cum laude, Boston College Law School, 2009, Topics Editor, Boston College Law Review

BA, English, University of Michigan, 2003

Bar Admissions


New York

District of Columbia

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