David DiBari is the practice area leader for US Litigation & Dispute Resolution, the Co-head of Clifford Chance's Global Risk Team.
He has over 30 years of experience in complex civil, regulatory and criminal matters arising under the Foreign Corrupt Practices Act, the USA PATRIOT Act, US economic sanctions and export controls, US securities and banking laws and regulations, and other laws and regulations affecting the conduct of international business. David has extensive experience in defending global companies in multi-jurisdictional investigations and litigation, advising companies on crisis management, and in developing and implementing cross-border risk mitigation and compliance programs.
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.
- 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 a leading financial Institution in connection with an internal investigation into US dollar payment processing involving OFAC sanctioned parties, voluntary disclosures to OFAC, the New York County District Attorney's Office ("DANY") and the DOJ and related investigations by DANY, DOJ and OFAC. Investigation included a German-language team on site, multiple employee interviews with translators, and preparation of several disclosure reports.
- 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
- 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
- Conducting a due diligence review for an aerospace and defense company's acquisition of an aviation-information management company
News and client work
- U.S. Supreme Court Asked to Resolve Circuit Split Over the Scope of the False Claims Act (Government Contracting Law Report, January 2021)
- SIFMA’s C&L Annual Seminar: Understanding Bank Regulatory Expectations of Compliance Programs
Panelist, March 26, 2019, Clifford Chance New York
- IIB's Risk Management and Regulatory Examination/Compliance Seminar: Supervisory Developments Regarding BSA/AML and OFAC Compliance
Speaker, October 15, 2018, New York
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