David M. Stetson

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.