David D. DiBari is Clifford Chance’s Global Co-Head of the Firm's Risk Team.
David has over 30 years of experience in crisis management and defending financial institutions and other multi-national companies in complex criminal and administrative matters arising under the Foreign Corrupt Practices Act, US banking and securities laws and regulations, US anti-money laundering, economic sanctions and export controls, and other laws and regulations affecting the conduct of international business. David has extensive experience in conducting multi-jurisdictional internal investigations and managing whistleblowers, and advising companies on developing and implementing cross-border risk assessments and compliance programs, systems and controls.
David has represented both domestic and multi-national companies before the US Securities and Exchange Commission, Federal Reserve, New York Department of Financial Services, Department of State, Department of Treasury, Department of Commerce, Department of Defense, Department of Justice, US Congress and other Federal and state authorities and SROs.
- Lead the investigation for Swedbank into historical exposure to money laundering risk, public disclosures regarding such risk and US Economic sanctions compliance, recorded in an investigation report to the Board of Swedbank, publicly disclosed by Swedbank in January 2021.
- Successfully represented the Royal Bank of Scotland plc in a final, global resolution of investigations by OFAC, US federal and state banking regulators, and US federal and state criminal authorities into US dollar payment processing involving OFAC sanctioned parties.
- Representing several leading international financial Institutions in connection with an internal investigation into US dollar payment processing involving OFAC sanctioned parties, including voluntary disclosures to OFAC, the New York County District Attorney's Office ("DANY") and the DOJ and related investigations by DANY, DOJ and OFAC.
- Representing a Baltic private banking institutions in connection with allegations regarding the adequacy of its then current and historic AML compliance and risk management framework.
- Representing a South American based international food product company in an internal investigation of alleged mislabeling.
- Representing an international mining company in investigations, civil litigation, and arbitration in multiple jurisdictions in connection with allegations of government corruption in Central Asia
- Representing international mining company in connection with corruption allegations involving projects in Africa and Southeast Asia
- Conducting an internal investigation and preparing a voluntary disclosure to the Department of Justice on behalf of a major international defense contractor relating to issues under the FCPA, Arms Export Control Act and other matters involving dealings in Central Asia
- Conducting an internal FCPA investigation and preparing a voluntary disclosure to the Department of Justice on behalf of a major international defense contractor in connection with the activities of an agent in the Middle East
- Representing international defense contractor in connection with corruption issues in China, Russia, and other jurisdictions
- Representing a major international financial institution and other significant parties in the wide-ranging Oil-for-Food investigations involving the Volcker Commission, US Congress, and other US and non-US authorities.
- Conducting a due diligence review for an aerospace and defense company's acquisition of an aviation-information management company
News and client work
Career and qualifications
- Colgate University (BA, cum laude, Phi Beta Kappa, Political Science) 1986
- Albany School of Law, Union University (JD, cum laude, Law Review) 1989
- Partner since 2000
Awards and citations
- David DiBari and team stand out with real strength in depth.
Legal 500, 2022 – United States: Dispute Resolution Corporate investigations and white-collar criminal defense: advice to corporates – Tier 3 Corporate investigations and white-collar criminal defense: advice to individuals – Tier 3