David S. Cohen
Senior Counsel
David Cohen advises 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.
Mr. Cohen served for twelve years in senior presidentially appointed positions. From 2015–2017 and again from 2021–2025, Mr. Cohen was Deputy Director of the Central Intelligence Agency (CIA); he also served briefly as Acting Director of the CIA in 2021. As Deputy Director, he helped to manage the Agency's 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 first 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 Qaeda 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 critical new statutory authorities to prevent money laundering and the financing of terrorism.
Prior to his most recent government service, Mr. Cohen practiced law in Washington DC for over 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.
Recognition
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
Credentials
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Education
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JD, Yale Law School, 1989
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BA, Cornell University, 1985
magna cum laude
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Admissions
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District of Columbia
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New York
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Clerkships
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The Hon. Norman P. Ramsey, US District Court for the District of Maryland, 1989 - 1990
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Government Experience
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Central Intelligence Agency
Acting Director -
Central Intelligence Agency
Deputy Director -
Department of the Treasury
Under Secretary for Terrorism and Financial Intelligence -
Department of the Treasury
Assistant Secretary for Terrorist Financing -
Department of the Treasury
Acting Deputy General Counsel
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Credentials
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Education
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JD, Yale Law School, 1989
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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
-
-
Government Experience
-
Central Intelligence Agency
Acting Director -
Central Intelligence Agency
Deputy Director -
Department of the Treasury
Under Secretary for Terrorism and Financial Intelligence -
Department of the Treasury
Assistant Secretary for Terrorist Financing -
Department of the Treasury
Acting Deputy General Counsel
-