Overview
David Stetson, a former senior lawyer at the US Department of the Treasury, Office of Foreign Assets Control (OFAC) and in-house sanctions lawyer, leads investigations and advises clients on OFAC sanctions and related anti-money laundering (AML) and export controls issues. He also advises clients on other international regulatory compliance and reputation risk matters.
Clients report that Dave "is one of our go-to sources for economic sanctions advice," and describe Steptoe's advice as "both well thought through and practical."
As an attorney-advisor in the Office of the Chief Counsel at OFAC, Dave advised on a wide range of enforcement, licensing, sanctions targeting/listing, and legislative matters, including the then-largest civil monetary penalty assessed by OFAC. In his role, he advised on the drafting and implementation of sanctions statutes, Executive Orders, and regulations for various US sanctions programs. He also worked closely with counterparts from the Departments of State, Justice, and Commerce, and National Security Council staff.
After leaving OFAC, Dave spent more than eight years at Goldman Sachs, as global co-head of sanctions compliance for nearly five years and most recently as vice president, associate general counsel and senior legal director in the legal division’s Business Intelligence Group (BIG). In his roles at Goldman Sachs, Dave helped build an industry-leading global sanctions compliance program and served as internal legal advisor on sanctions matters for all of the firm's business lines, including lending and investing; underwriting; securities trading; asset management; and consumer financial products. He was involved in the company's rapid compliance response to novel and complex sanctions relating to China, Russia, and Venezuela, among many others. He also advised Goldman Sachs on how to address sanctions matters that arose at the bank’s clients and portfolio companies, gaining detailed knowledge of sanctions risks and compliance practices across a wide range of business sectors.
Drawing on his government and in-house experience, he focuses on helping clients apply rapidly evolving sanctions requirements across a broad array of financial products and services, including investment banking, securities trading, commercial lending, merchant banking, commodities trading, asset management, and consumer banking. Beyond the financial sector, Dave helps clients understand where sanctions compliance risks arise, develop and implement best practices for proactive risk-based compliance programs, and navigate the enforcement process when potential sanctions violations occur.
- New York
- District of Columbia
- Hon. John G. Roberts, Jr., US Court of Appeals, District of Columbia, 2003-2004
- J.D., Harvard Law School, 2003, cum laude, Executive Editor, Harvard Law Review
- A.M., Harvard University, 1998
- A.B., Duke University, magna cum laude
Areas of Work
Speaking Engagements
- “The Practical Impact of Recent Cases on Financial Institutions and Multinationals Operating in Canada,” CI’s 8th Canadian Forum on Global Economic Sanctions, March 6, 2024
- “High Priority Goods List and Battlefield Electronics - What Do the Latest US, EU and UK Alert Notices Expect from You?” S&P Global, February 13, 2024
- "Key Trends in US Sanctions and Export Control Enforcement," Informa Global Sanctions Forum, London, UK, October 17, 2023
- "M&A Risk Management Action Plan - A Practical Scenario Exercise," 16th ACES Summit on Anti-Corruption, Export Controls, and Sanctions Compliance, May 23, 2023
- "Incorporating Unprecedented Sanctions into Financial Institutions’ Compliance Programs," Informa Connect Global Sanctions Forum, London, UK, October 19, 2022
- "Session on Sanctions," Anti-Money Laundering & Financial Crimes Conference, New York, May 25, 2022
- "The Ukraine Crisis and Impacts on US Companies," US-China Business Council webinar, March 8, 2022
- "Implementing an Effective Export Control Program for Financial Institutions," IHS Markit, February 24, 2022
- "Status Report on Addressing Ukraine-Related Developments," American Conference Institute’s Conference on US Economic Sanctions Enforcement and Compliance, May 5, 2022
- "Deciphering More Country-Specific Sanctions Restrictions: Cuba, Venezuela, Syria, North Korea, Afghanistan, Belarus," ACI's US Economic Sanctions Proficiency Series, February 16, 2022
- "Sanctions and Export Controls Due Diligence: The Key Issues," WorldECR Webinar, October 24, 2021
- "AML and Corruption in Trade Controls Compliance: Investigation, Enforcement and Mitigation," WorldECR Webinar, October 14, 2021
News & Publications
Client Alerts
AML Program Requirements for Investment Advisers: FinCEN’s Proposed Rulemaking
February 16, 2024
By: Andrew C. Adams, Coy Garrison, Jack R. Hayes, David M. Stetson, Evan T. Abrams, Sophia Breggia, Vito Arethusa
International Compliance Blog
Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act Are Now in Effect
January 25, 2024
By: Danielle F. Fern, Sabina Jacobs Margot, David M. Stetson,
International Compliance Blog
December 29, 2023
By: Ali Burney, Wendy Wysong, David M. Stetson, Zoey Hong, Wilson Zhao
Publications
OFAC Sanctions and Digital Assets: Regulation, Compliance, and Recent Developments
Global Legal Insights: Blockchain & Cryptocurrency Laws and Regulations 2024
November 29, 2023
By: Andrew C. Adams, David M. Stetson, Evan T. Abrams, Sophia Breggia
International Compliance Blog
U.S. Government Issues New Russia-related Sanctions Designations and Export Controls Guidance
September 22, 2023
Steptoe Blockchain Blog
August 31, 2023
International Compliance Blog
OFAC Sanctions Former Governor of Lebanon Central Bank and Associates
August 17, 2023
By: Jack R. Hayes, David M. Stetson, Ryan Pereira
International Compliance Blog
Biden Administration Announces New Outbound Investment Regime Targeting China
August 11, 2023
By: Evan T. Abrams, Wilson Zhao, Ali Burney, Wendy Wysong, Jack R. Hayes, David M. Stetson, Brian J. Fleming, Bo Yue, Meredith Rathbone, Edward J. Krauland, Alexandra Baj
Resources
Events
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Stacie R. Hartman, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Lucinda A. Low, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao
Webinars
Possible Sanctions Against Russia: What You Need to Know
February 9, 2022
Speakers: Meredith Rathbone, Edward J. Krauland, Alexandra Baj, Matthew Coleman, Alexandra Melia, Guy Soussan, David M. Stetson
Webinars
Investigations & Enforcement Webinar Series
July 21, 2021
Speakers: Jason Abel, Christopher R. Conte, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, David M. Stetson, Wendy Wysong
Noteworthy
- Legal 500 US, "Next Generation Partner," International Trade - Customs, Export Controls and Economic Sanctions
Previous Employment
- Vice President, Associate General Counsel, and Senior Legal Director, Business Intelligence Group, Legal Division, Goldman Sachs (2018-2021)
- Vice President, Senior Compliance Officer, and Senior Regulatory Advisor, Financial Crime Compliance, Global Compliance Division, Goldman Sachs (2017-2018)
- Vice President and Co-Head, Government Sanctions Group, Financial Crime Compliance, Global Compliance Division, Goldman Sachs (2012-2017)
- Attorney-Advisor, Office of the Chief Counsel, Foreign Assets Control (OFAC), Office of the General Counsel, US Department of the Treasury (2008-2012)
- Counsel, Senator Dianne Feinstein, Senate Judiciary Committee, Subcommittee on Terrorism, Technology, and Homeland Security (2006-2008)