Former CIA Deputy Director and Treasury Undersecretary David S. Cohen, Returns to WilmerHale

Former CIA Deputy Director and Treasury Undersecretary David S. Cohen, Returns to WilmerHale

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David S. Cohen, who served as deputy director of the CIA from 2015 to 2017 and again from 2021 to 2025, as well as under secretary for Terrorism and Financial Intelligence at the Department of the Treasury, has returned to WilmerHale as senior counsel.

Mr. Cohen will advise clients on a wide range of national security, regulatory enforcement, and cross-border matters, including issues at the intersection of national security and artificial intelligence, cybersecurity, CFIUS review, anti-money laundering, trade and financial sanctions, internal investigations, and defense of government investigations and enforcement actions. He will draw on decades of experience at the highest levels of government and in private practice, including his prior tenure as a WilmerHale partner.

“We are delighted to welcome David back to WilmerHale,” said Anjan Sahni, managing partner of WilmerHale. “His extraordinary government service, deep understanding of national security and financial integrity issues, and proven judgment in complex, high-stakes matters will be invaluable to our clients. David’s return further strengthens the country’s premier team for companies facing the most challenging and complex government, regulatory, and enforcement issues.”

From 2015 to 2017 and 2021 to 2025, Mr. Cohen served as Deputy Director of the CIA, helping lead the Agency during a period of significant global security challenges and rapid technological change. He also served briefly as Acting Director of the CIA in 2021. In these roles, he helped to manage the Agency’s worldwide operations, including foreign-intelligence collection, all-source analysis, covert action, counter-intelligence, and foreign liaison relationships, and he worked on generational strategic modernization and technology-focused initiatives.

“I am excited to return to WilmerHale and to work again with colleagues I respect so deeply,” Mr. Cohen said. “WilmerHale combines exceptional legal talent, sophisticated regulatory and litigation capabilities, a deep understanding of government, and a commitment to helping clients navigate their most difficult challenges. I look forward to contributing to that work as I return to private practice.”

Mr. Cohen previously served at the Department of the Treasury as Under Secretary for Terrorism and Financial Intelligence from 2011 to 2015 and as Assistant Secretary for Terrorist Financing from 2009 to 2011. At Treasury, he led policy, regulatory, enforcement, and intelligence functions focused on combating illicit finance, including money laundering, sanctions evasion, and financial support for threats to national security. He directly supervised the Office of Foreign Assets Control, which is central to implementation of US sanctions policies, and the Financial Crimes Enforcement Network; and he played a central role in developing and implementing sanctions against Iran, Russia, North Korea, ISIS, al-Qaeda, and other terrorist organizations.

Before his most recent government service, Mr. Cohen led WilmerHale’s Business and Financial Integrity Group, advising clients on anti-money laundering, financial and trade sanctions, CFIUS, cybersecurity, internal investigations, and government enforcement defense. Earlier in his career, he practiced in Washington DC for nearly 20 years, including as a WilmerHale partner focused on complex civil litigation, white-collar criminal defense, internal investigations, and anti-money laundering and sanctions compliance.

Mr. Cohen has twice received the CIA’s Distinguished Intelligence Medal, the Agency’s highest honor, the Director’s Award for Distinguished Service, and the Treasury Department’s Alexander Hamilton Award, the department’s highest honor.

Mr. Cohen earned his JD from Yale Law School in 1989 and his BA magna cum laude from Cornell University in 1985. He clerked for Judge Norman P. Ramsey of the US District Court for the District of Maryland from 1989 to 1990 and is admitted to practice in the District of Columbia and New York.

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