David D. DiBari delivers over 35 years of experience advising global companies on criminal and regulatory defense, cross-border investigations, and financial economic crime compliance and risk management. He represents clients in complex, multi-jurisdictional matters involving economic sanctions, export controls, anti-money laundering (AML), fraud, corruption, and other sensitive enforcement and reputational issues.
David counsels multinational corporations and financial institutions in responding to government and Congressional investigations, conducting internal investigations, managing whistleblower issues, and handling crises that require both legal and strategic communications guidance. He also advises on enterprise risk assessments, compliance programs, transactional due diligence in high-risk jurisdictions, and governance training for boards and senior leadership.
David has represented clients before the U.S. Department of Justice, Securities and Exchange Commission, Treasury Department, Federal Reserve, Commerce Department, State Department, Congress, and other federal, state, and foreign regulators. His matters often involve rapid decision-making and innovative solutions to manage legal, reputational, and operational risks.
Prior to joining Womble, David held several global and regional leadership positions at an international law firm, including serving as Global Co-Head of the Risk Team, Head of Regulatory Investigations and Financial Crime for the Americas, Managing Partner of the Washington, D.C. office, a member of the firm’s World Leadership Group, and a longtime member of the firm’s Americas Management Committee.
A recognized thought leader in global risk and enforcement, David is a frequent speaker on regulatory and compliance issues, an active member of industry groups, and a dedicated mentor with a strong commitment to pro bono work – particularly in areas involving international human rights and sanctions compliance.
Representative Experience
Any result the lawyer or law firm may have achieved on behalf of clients in other matters does not necessarily indicate similar results can be obtained for other clients.
Sanctions and Export Controls
- Led an internal investigation for Fokker Services BV into economic sanctions and export control compliance issues relating to the export of US origin aircraft parts to Iranian interests. Negotiated simultaneous resolutions with DOJ, OFAC, and Commerce. After the District Court rejected the Deferred Prosecution Agreement (DPA) as too good a deal for Fokker, led the joint appeal with DOJ to the DC Circuit, which upheld the DPA and set new precedent for the role of the District Court in approving DPAs.
- Represented Royal Bank of Scotland in global sanctions investigation and voluntary disclosure to OFAC, DOJ and US banking regulators resolved without criminal action.
- Conducted export controls/ITAR investigations and disclosures for multiple international defense, aerospace, and services companies, with favorable resolutions.
- Represented Swedbank in connection with an internal investigation of OFAC sanctions compliance by its operations in the Baltics, voluntary disclosure to OFAC, and defense of OFAC investigation.
- Represented a major European-based international financial services company in connection with an internal investigation into alleged violations of export controls and OFAC sanctions regulations, and defense of investigations by DOJ, BIS, OFAC, state attorney general's office, and state and federal banking regulators, involving operations in the US, Europe, Middle East, and Asia, with negotiated global resolution.
- Represented a major European-based international financial services company in connection with an internal investigation into alleged violations of OFAC sanctions regulations by its operations in the US, Europe, Asia, Middle East and South America, and defense of investigations by DOJ, OFAC, FinCEN, state attorney general's office, and state and federal banking regulators, with negotiated global resolution.
- Represented a major European-based international financial services company in connection with an internal investigation initiated in response to a state attorney general's office subpoena regarding international OFAC sanctions compliance, and subsequent investigations by DOJ, OFAC and state and federal banking regulators and local European regulators, with negotiated global resolution.
- Led the independent multi-year multi- jurisdictional US economic sanctions look-back exercise for ABN AMRO pursuant to its settlement with OFAC.
- Advised Baltic shipping company in sanctions-related licensing with OFAC.
- Counseled corporates and financial institutions on exit strategies from sanctioned jurisdictions, particularly Russia.
- Provided sanctions due diligence and risk mitigation strategies for transactions, including licensing and compliance enhancements.
Anti-Money Laundering
- Led the independent and public investigation on behalf of the Board of Swedbank after investigative journalists alleged in a series of televised reports that Swedbank had processed several billion dollars of suspicious transactions involving oligarch interests, and presenting the final report at a Swedbank press conference, fielding questions from the media on the scope, methodology and findings.
- Conducted an internal investigation on behalf of a major multi-national private bank involved in billions of dollars of transactions directly implicated in the 1MDB corruption and money laundering scandal, disclosures to authorities in the US, Europe, UK, Singapore and Hong Kong, resolutions with non-US authorities and no action by US authorities.
- Represented a Baltic private banking institution in connection with banking regulator concerns and allegations regarding their high-risk customer base and business model, the adequacy of its then current and historic AML compliance and risk management framework, and negotiations with local regulator.
- Represented an international money services business and their individual owner in a criminal investigation and indictment related to alleged involvement in a cross-border money laundering enterprise, resulting in dismissal of all charges.
- Represented an international financial institution in an internal investigation of money laundering and currency fraud scheme involving derivative trading in Brazil, and money transfers to offshore jurisdictions and the US, disclosures to US authorities and resolution without action against the company.
- Advised a variety of financial institutions on AML regulatory requirements under the Bank Secrecy Act and overlapping/intersecting corruption, sanctions, and export control issues.
- Conducted investigations for financial institutions into potential suspicious transactions.
- Advised corporates on AML due diligence in acquisitions, joint ventures, and other investments, and on risk mitigation steps and contractual clauses.
Corruption and Fraud
- Represented U.S. and international defense contractors in multiple internal FCPA investigations, including matters in the Middle East, Central Asia, China, Russia, Colombia, Brazil, and Peru.
- Conducted global corruption investigations for mining, chemical, and pharmaceutical companies, including whistleblower issues, DOJ/SEC disclosures, and compliance remediation
- Represented international mining companies in high-stakes investigations across Africa, Southeast Asia, and Latin America involving FCPA, AML, and sanctions risks.
- Represented Audit Committees and Boards in corruption investigations involving C-suite executives and whistleblower allegations.
- Advised on corruption-related whistleblower complaints intersecting with U.S. Congress and media scrutiny.
- Investigated environmental whistleblower allegations related to PFAS disclosures to state authorities.
- Prepared DOJ FCPA Opinion Procedure Release requests in high-risk jurisdictions.
- Conducted several hundred agent and consultant FCPA due diligence investigations.
- Defended international bank in False Claims Act litigation and pre-trial mediation related to a government fraud scheme.
- Represented major investment banks and mutual funds in SEC investigations, including alleged market manipulation and personal trading misconduct.
- Advised financial institutions in connection with the U.N. Oil-for-Food program and related Congressional and regulatory investigations.
- Developed global FCPA risk assessments and compliance programs for US-listed corporations and companies operating in Asia, Europe, and Latin America.
Honors & Awards
- Named to the Lawdragon 500 Leading Litigators in America list, 2025-Present
Thought Leadership
- Speaker, "U.S. Enforcement Updates: Policies, Trends & Expectations," Joint Seminar with the Compliance Women Committee (January 30, 2026)
