David Horn, Former Treasury Official, Rejoins WilmerHale, Further Enhancing the Firm’s Leading Sanctions Practice

David Horn, Former Treasury Official, Rejoins WilmerHale, Further Enhancing the Firm’s Leading Sanctions Practice

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WilmerHale is pleased to announce that David Horn, a leading US sanctions and export controls lawyer, has rejoined the firm as a Partner in its International Trade, Investment and Market Access Group.

Horn’s practice will focus on representing clients facing government scrutiny arising from economic sanctions and related regulatory measures. He will be based in the firm’s Washington DC office, where he previously practiced before joining government. He is the latest addition to WilmerHale’s industry-leading sanctions, export controls, and anti-money laundering practices, which include several former senior US State, Justice and Treasury Department officials.

In his roles in the private and public sectors, Horn has advised both corporate clients and government officials on the laws, regulations and policies underpinning US economic sanctions. He rejoins WilmerHale from the US Department of the Treasury, where he served most recently as Acting Chief Counsel for the Office of Foreign Assets Control (OFAC). In that role, Horn advised department leaders on all significant legal issues, including constitutional implications of US sanctions, new statutory authorities, and enforcement of existing authorities, including the International Emergency Economic Powers Act (IEEPA).

Horn was involved in every stage of sanctions investigation and enforcement, including advising on whether to pursue cases, negotiation of high-stakes settlements, and, in coordination with the Department of Justice, criminal prosecutions.

“We are excited to welcome David back after his exceptional public service at the Treasury Department,” said Anjan Sahni, WilmerHale’s Managing Partner. “David is extraordinarily well-positioned to advise clients on their full range of issues, including internal compliance assessments and responding to enforcement actions related to sanctions or other regulatory complexities in today’s dynamic environment.”

Horn spent 13 years at WilmerHale in the firm’s International Trade, Investment and Market Access group, counseling multinational corporations on US regulatory compliance and enforcement matters at the intersection of international trade and national security.

“Few attorneys bring David’s breadth and depth of experience,” said David Ross, who chairs the group. “David’s expertise overseeing sanctions and related policies and private practice acumen will greatly benefit clients.”

“WilmerHale remains an excellent home for my practice and I am thrilled to return to it to work with exceptionally talented colleagues,” Horn said. “The firm's combination of legal and regulatory expertise, deep understanding of how government works, and unwavering commitment to addressing clients’ needs make it the ideal place for me as I transition back to private practice after my time at Treasury.”

Horn is the latest recent arrival joining WilmerHale’s leading sanctions, export controls, and anti-money laundering practices. In September 2025, Marik String rejoined the firm following his service as Senior Advisor to Secretary of State Marco Rubio and as a Trump-Vance presidential transition team member. Then in December 2025, WilmerHale added Sean Thornton, who joined from BNP Paribas and previously served for seven years as OFAC Chief Counsel, and brings deep experience with AML, sanctions compliance, export controls, and other complex regulatory matters.

Horn earned his BA from the University of Michigan, and his JD, cum laude, from Boston College Law School.

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