David S. Cohen

David Cohen, who leads the firm's Business and Financial Integrity Group, 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.

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.

Professional Activities

Mr. Cohen is a Trustee of Cornell University, a member of the Council on Foreign Relations, a Senior Fellow with Harvard Kennedy School’s Belfer Center for Science and International Affairs, a member of the Board of Advisors of the Center on Law and Security at New York University Law School, an Adjunct Senior Fellow at the Center for a New American Security, an advisory board member of the National Security Institute at George Mason University's Antonin Scalia Law School, and a principal with WestExec Advisors LLC. He serves on the Center for Strategic and International Studies Commission on Affirming American Leadership and the Center for a New American Security Future of US Sanctions Task Force.

Events and Other Engagements

  • February 5, 2020 – SIFMA AML Panel
  • December 16, 2019 – CNAS: Strengthening the Economic Arsenal 
  • November 8, 2019 – ABA's General Counsels Group 2019 Annual Meeting
  • October 8, 2019 – 6th Annual GIR Live
  • September 13, 2019 – Fireside Chat: S&P Global Offsite 
  • September 10, 2019 – Economic Sanctions Trends and Developments (Webinar)
  • July 25, 2019 – AML and Sanctions: Trends and Developments Emerging Under the Trump Administration (Webinar)
  • May 13, 2019 – BofA Financial Crime Conference
  • April 8, 2019 – Kharon Global Sanctions Summit
  • April 2019 – Symposium on Unilateral Targeted Sanctions
  • February 12, 2019 – AGA and PwC 4th Annual AML Summit
  • January 23, 2019 – David Cohen, Avril Haines talk with Michael Morell on "Intelligence Matters" (CBS News)
  • January 22, 2019 – Cosmos Club Re: Iran and North Korea
  • June 13, 2018 – Worth: The Reality of Risk 2018, Strategies and Opportunities in an Evolving Security Landscape
  • May 24, 2018 – Atlantic Council - “Big Data: A Twenty-first Century Arms Race?”
  • May 21, 2018 – RANE Podcast “Art of the Undeal: Implications of the U.S. Exit from the Iran Agreement” (with Zach Goldman)
  • April 26, 2018 – University of Virginia National Security Policy Center, “The Future of Counterterrorism”
  • April 17, 2018 – Guggenheim Securities, RSA Cybersecurity Conference Dinner
  • April 11, 2018 – Washington University, “The National Security Landscape”
  • February 13, 2018 – Council on Foreign Relations, Terrorism Financing Roundtable: “Is the War on Terrorism Financing Working”
  • February 5, 2018 – US-Russia Business Council, “Russia Sanctions – Lessons Learned and Lessons Being Learned”
  • December 14, 2017 – RANE Podcast “Perspectives on Regulations and Financial Crime Enforcement
  • November 8-9, 2017 – Belfer Center for Science and International Affairs, Harvard Kennedy School Intelligence Project Seminar Lunch
  • October 12-13, 2017 – Yale Law School: Congress and Foreign Policy Conference
  • October 11-12, 2017 – Pitney Bowes Financial Crimes & Compliance Executive Forum
  • October 10, 2017 – Brookings Institution North Korea Conference
  • September 11, 2017 – Atlantic Council’s Economic Sanctions Initiative and the Institute of International Economic Law (IIEL) at Georgetown Law
  • Partner David Cohen Featured in CBS News Podcast, Intelligence Matters

    Partner David Cohen speaks with Michael Morell, former acting director of the US Central Intelligence Agency and host of Intelligence Matters, a CBS News podcast, which features “top leaders of the US intelligence community as they reflect on their life, career and the critical roles they play in shaping national security policies.”

    October 31, 2018
    Read More


Recognized by Global Investigations Review as one of 25 "DC sanctions lawyers to have on speed dial" (2019)

Recognized in The Legal 500 United States for his dispute resolution and international trade practice (2018)

Central Intelligence Agency Distinguished Intelligence Medal (2017)

United States Department of the Treasury Alexander Hamilton Award (2015)

Insights & News


  • Education

    • JD, Yale Law School, 1989

    • BA, Cornell University, 1985

      magna cum laude
  • Admissions

    • District of Columbia

    • New York

  • Clerkships

    • The Hon. Norman P. Ramsey, US District Court for the District of Maryland, 1989 - 1990