Horn_David

David M. Horn

Horn_David

David M. Horn

Partner

Washington DC + 1 202 663 6749

David blends deep national security know-how, practical judgment, and a steady, collaborative style that clients trust when navigating their most complex regulatory challenges. A partner in WilmerHale’s Regulatory and Government Affairs Department, David is known for the calm, clear, and actionable counsel he provides to multinational companies operating under intense scrutiny amid geopolitical complexity.

David’s perspective is shaped by more than 15 years at the front lines of economic statecraft—across government, private practice, and policymaking. Most recently, he served as Acting Chief Counsel for the Treasury Department’s Office of Foreign Assets Control (OFAC), where he led the legal team responsible for interpreting and advising OFAC on every dimension of US sanctions. In that role, he became a trusted advisor to senior officials across presidential administrations as they navigated some of the most consequential sanctions decisions of the past decade. He provided key analysis on the laws that underpin US sanctions—including the International Emergency Economic Powers Act, the Administrative Procedure Act, the Trading with the Enemy Act, the Freedom of Information Act, and numerous other statutory authorities involving China, Iran, Russia, Venezuela, and global narcotics networks. He supervised the successful defense of the Treasury Department in constitutional and administrative challenges, prepared agency leadership for congressional hearings, and guided the agency on its implementation of novel new authorities such as the Outbound Investment Security Program. David prepared executive orders, led regulatory reform efforts, and crafted effective litigation approaches that influenced the current framework of sanctions. His work touched every corner of OFAC’s mission—from designations and enforcement actions to complex license determinations and compliance guidance.

Before returning to government, David spent more than a decade at WilmerHale building a reputation for providing practical, expert advice to multinational companies so that they could effectively navigate fast evolving US sanctions, export controls, trade remedies, the Committee on Foreign Investment in the United States, and other regulatory matters at the intersection of national security, international trade, and cross-border investment. 

Recognition

  • Recognized as a "Rising Star" in the 2020-2022 editions of The Legal 500 United States for his international trade practice
  • Selected as a "Rising Star" in the 2016–2019 editions of Washington DC Super Lawyers

Insights & News

View all of David's insights & news

Credentials

  • Education

    • JD, Boston College Law School, 2009

      cum laude Topics Editor, Boston College Law Review

    • BA, English, University of Michigan, 2003

  • Admissions

    • Massachusetts

    • New York

    • District of Columbia

  • Government Experience

    • Department of the Treasury

      Office of the Chief Counsel (Foreign Assets Control)

      Acting Chief Counsel

    • Department of the Treasury

      Office of the Chief Counsel (Foreign Assets Control)

      Assistant Chief Counsel

    • Department of the Treasury

      Office of the Chief Counsel (Foreign Assets Control)

      Attorney-Advisor

Credentials

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