WilmerHale, one of the leading law firms in international trade and regulatory compliance, has announced the return of David M. Horn, a seasoned sanctions lawyer, as a partner in the firm’s
Trade, Investment, and Market Access practice in Washington, D.C. Horn rejoins the firm after completing a three-year tenure at the U.S. Department of the Treasury, most recently serving as acting chief counsel for the Office of Foreign Assets Control (OFAC) the federal agency responsible for administering and enforcing
U.S. economic sanctions programs.
Horn’s return comes at a time when economic sanctions and export control compliance are at the forefront of
global regulatory risk management, with multinational corporations facing evolving legal obligations across jurisdictions. His expertise in U.S. sanctions law and enforcement positions WilmerHale to better advise clients confronting complex regulatory challenges, government investigations, and enforcement actions.
A Strategic Addition to WilmerHale’s Sanctions and Compliance Team
WilmerHale’s Sanctions and Compliance practice is widely recognized for its depth of experience in navigating U.S. and global sanctions and export control regimes. The firm’s interdisciplinary group includes former senior government officials and enforcers from key federal agencies such as the Department of Justice, Department of State, and U.S. Treasury, providing clients with strategic insight into regulatory expectations and enforcement trends.
Horn’s return enhances the firm’s capability to represent corporations, financial institutions, and individuals in matters related to economic sanctions compliance, enforcement defense, and risk mitigation. His work at OFAC involved advising on legal interpretations of sanctions regulations, reviewing enforcement matters, and contributing to agency policy development experience that complements WilmerHale’s client offerings in sanctions risk management and compliance program design.
At OFAC, Horn advised on a range of sanctions programs targeting state and non-state actors, including those related to Iran, Russia, North Korea, and transnational criminal networks. He helped shape the legal frameworks governing blocking orders, asset freezes, and prohibitions on transactions involving designated persons, giving him practical insight into the agency’s enforcement priorities and decision-making processes.
Expertise in U.S. Sanctions Law and Enforcement Defense
WilmerHale’s clients increasingly rely on deep legal expertise to anticipate and address regulatory risks posed by U.S. economic sanctions and export controls. The firm’s sanctions practice helps clients respond to government inquiries, negotiate settlements with regulatory authorities, and defend against potential enforcement actions. Its attorneys are also experienced in advising on compliance with overlapping international sanctions regimes enforced by entities such as the European Union and United Kingdom.
The addition of Horn bolsters a team that already includes lawyers with extensive experience in anti-money laundering (AML), national security law, and cross-border regulatory compliance. These capabilities are essential for companies operating in high-risk industries such as financial services, defense, technology, and energy, where sanctions violations can result in significant civil and criminal penalties, reputational harm, and operational disruptions.
Growing Global Demand for Sanctions and Export Controls Compliance Counsel
The global regulatory landscape for economic sanctions has become more complex in recent years, driven by geopolitical tensions, evolving foreign policy priorities, and increased enforcement activity. Businesses with international operations must navigate a patchwork of U.S. and foreign sanctions programs that can change rapidly, requiring proactive compliance strategies and specialized legal counsel.
WilmerHale’s sanctions team helps clients interpret new regulatory requirements, implement robust compliance frameworks, and respond to heightened scrutiny from regulators. The firm’s approach combines legal analysis with practical risk assessment, enabling clients to make informed decisions that support both compliance and business objectives.
Career Background and Government Experience of David M. Horn
Before his service at the Treasury Department, Horn had a record of advising clients on sanctions-related matters from within private practice. His background includes representing multinational companies in regulatory compliance matters, including risk assessments related to U.S. sanctions and export control laws, internal investigations, and government enforcement proceedings.
At OFAC, Horn gained firsthand experience in interpreting and applying some of the most consequential sanctions regimes enforced by the U.S. government. His role as acting chief counsel placed him at the center of legal analysis for sanctions policy decisions and enforcement actions, giving him a rare and valuable perspective that he now brings back to private practice.
WilmerHale’s Broader Strategy in Regulatory and Enforcement Matters
WilmerHale has consistently expanded its regulatory enforcement and compliance capabilities to meet growing client demand for sophisticated legal support in areas intersecting with sanctions law. The firm’s trade and investment practice focuses on advising clients on international trade regulations, export controls, economic sanctions, and national security reviews of cross-border transactions, providing comprehensive representation in both advisory and contentious matters.
By reintegrating Horn into its partnership ranks, WilmerHale demonstrates a continued commitment to strengthening its sanctions and compliance practice with top legal talent who have unique insights gained from senior government service. Clients benefit from this combination of private-sector advisory experience and government-level regulatory understanding especially in a legal environment where sanctions and export control enforcement remain a central focus for U.S. regulators.
Looking Ahead
As global sanctions programs continue to evolve and enforcement actions increase in frequency and complexity, demand for expert legal counsel in sanctions, export controls, and AML compliance is expected to grow. WilmerHale’s strategic recruitment of seasoned practitioners like Horn ensures that the firm remains well-positioned to support clients in navigating these challenges and addressing emerging regulatory priorities.
Horn’s return is likely to expand WilmerHale’s role in high-stakes sanctions matters, strengthen client relationships, and enhance the firm’s reputation as a trusted advisor in one of the
most dynamic areas of international law and compliance.
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