Horn_David

David M. Horn

Horn_David

David M. Horn

Partner

Washington DC + 1 202 663 6000

David M. Horn is a partner in WilmerHale’s Regulatory and Government Affairs Department. He provides pragmatic, informed and actionable counsel to multinational companies and other clients on challenging national security law and regulatory matters. He brings to the firm more than 15 years of experience at the intersection of international trade, national security, and economic statecraft, including leadership roles at the US Department of the Treasury and over a decade in private practice at WilmerHale.

Most recently, Mr. Horn served as Acting Chief Counsel for the Treasury Department’s Office of Foreign Assets Control (OFAC), where he led the team advising OFAC on all aspects of US sanctions law and policy. Mr. Horn has unique insights into US sanctions, particularly as successive presidential administrations have deployed sanctions authorities in complex and novel ways. He counseled senior agency officials on the lawful implementation of numerous statutes and Executive Orders concerning China, Iran, Venezuela, Russia, and counter-narcotics, among many others. Mr. Horn advised on the sanctions and non-sanctions uses of the International Emergency Economic Powers Act (IEEPA) including the drafting of Executive Orders. He was a lead architect of key OFAC regulatory changes, developed successful litigation defense strategies, and oversaw the legal review of US sanctions designations, enforcement actions, license determinations, and sub-regulatory compliance guidance. He worked closely with the White House and components at the Departments of Justice, State, Commerce, and Homeland Security, and brings a unique lens to analyzing US government policymaking and legal and regulatory risk.

From 2010 to 2022, Mr. Horn practiced at WilmerHale as Special Counsel, Counsel and Associate. He counseled multinational companies on compliance and enforcement matters in connection with US sanctions, export controls, the Committee on Foreign Investment in the United States (CFIUS), and trade remedy matters. He managed investigations into apparent violations of US sanctions and export controls, represented clients before US government agencies, and developed and implemented comprehensive trade compliance programs. His experience includes advising on US-China trade policy, technology competition, 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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