David Cook provides strategic and legal advice to financial institutions, including financial technology clients, on complex regulatory compliance issues, often involving the Bank Secrecy Act, the Bank Holding Company Act, anti–money laundering, economic sanctions, enterprise risk management, anti-bribery and corruption, mortgage origination and servicing, privacy, payments, cryptocurrency, and consumer protection compliance matters. He has over two decades of experience in the public and private sectors, including leadership roles at a global financial services consulting firm owned by IBM and at the US Department of the Treasury. David’s professional experience spans engagements or secondments in the Americas, Europe, Asia and Australia.

Prior to joining the firm, Mr. Cook spent over a decade at Promontory Financial Group, where he headed the Financial Crime Digital Assets Practice. In that capacity, he crafted strategic solutions for multi-billion-dollar financial institutions across the globe with complex matters pending before state, federal and central banking regulators, including in matters related to money laundering, economic sanctions, enterprise risk management, privacy and data security, mergers, mortgage origination, servicing, and foreclosure, and others. He designed and implemented compliance programs, policies and procedures; conducted risk assessments, reviews and forensic investigations; and led large engagement teams in credit, loan and suspicious activity alert file evaluations. In a representative example, David led a group of 25 attorneys during a two-year engagement to review and remediate systemic issues related to mortgage foreclosure practices at one of the largest US banks in accord with federal, state, local and GSE regulatory obligations.

At Treasury, Mr. Cook served as the lead risk/compliance officer for the $40 billion Public-Private Investment Program of the Office of Financial Stability. In that capacity, he helped to build from the ground up a fund manager application and selection process to co-invest public money in the mortgage-backed securities market that successfully promoted liquidity and price discovery in the wake of the mortgage crisis of 2008. He was also an attorney in the Enforcement and Compliance Division of the Office of the Comptroller of the Currency. In that capacity, he served a leadership role in a high-profile trial involving alleged fraud on the part of a bank institutional affiliated party related to over $120 million. Mr. Cook previously worked as an associate in the Financial Institutions Group of an international law firm, where he advised financial institutions on regulatory matters involved in mergers and acquisitions. 

Mr. Cook clerked for the Honorable A. Raymond Randolph of the US Court of Appeals for the District of Columbia Circuit, during which term he advised on cases involving such varied matters as remands from the US Supreme Court on the Freedom of Information and Federal Advisory Committee Acts, and many others. He was also an associate consultant at an international strategy management consulting firm.

Mr. Cook maintains an active pro bono practice representing low-income and disabled individuals in accessing benefits, and he has contributed to amicus briefs in cases of importance, including those related to religious freedom.

Insights & News


  • Education

    • JD, Northwestern University Pritzker School of Law, 2004

      with Honors

      Order of the Coif, Nicholas Merit Scholar

      Senior Articles Editor, Northwestern University Law Review

    • MBA, Northwestern University, Kellogg School of Management, 2004

    • BA, History, Yale University, 1998

      with Honors, Distinction in the Major, Phi Alpha Theta Adams Cup Winner, Vice President, Yale Political Union
  • Admissions

    • District of Columbia

    • New York

  • Clerkships

    • The Hon. A. Raymond Randolph, US Court of Appeals for the District of Columbia Circuit, 2004



Unless you are an existing client, before communicating with WilmerHale by e-mail (or otherwise), please read the Disclaimer referenced by this link.(The Disclaimer is also accessible from the opening of this website). As noted therein, until you have received from us a written statement that we represent you in a particular manner (an "engagement letter") you should not send to us any confidential information about any such matter. After we have undertaken representation of you concerning a matter, you will be our client, and we may thereafter exchange confidential information freely.

Thank you for your interest in WilmerHale.