Biography
David Lim is a partner in the Firm's Global International Trade Practice, where he advises clients on a wide range of US regulatory compliance and enforcement issues related to economic sanctions, export controls, and national security matters. In particular, David advises sovereigns and companies operating in the financial services, technology, oil & gas, defense, semiconductor, biotechnology, manufacturing, transportation, and other sectors in navigating complex and cross-border issues arising from US economic sanctions and export controls. His practice specializes in conducting comprehensive internal investigations, performing compliance assessments and enhancements, and providing robust defense in regulatory enforcement actions.
Before joining White & Case, David served at the US Department of Justice (DOJ) in multiple senior roles, most recently as the Co-Director for Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing sanctions, export restrictions, and economic countermeasures against Russia. In this role, David coordinated with multiple US government agencies, including the US Department of the Treasury's Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) on cross-border investigations. Prior to that, David was the inaugural National Coordinator of the Disruptive Technology Strike Force, a joint venture between the DOJ and Department of Commerce to leverage criminal, civil, and administrative enforcement tools to disrupt the unlawful theft and export of sensitive US technology.
In earlier roles, David was a Trial Attorney in the Counterintelligence and Export Control Section of the DOJ's National Security Division (NSD), where he investigated and prosecuted federal crimes related to national security, including economic sanctions, export control, espionage, and trade secret theft. David also served as the Acting Deputy Chief for Export Control and Sanctions, where he oversaw all federal criminal cases involving export controls and sanctions nationwide.
Before joining the DOJ's NSD, David served as Senior Counsel in the Office of the Assistant Attorney General for the Criminal Division, where he advised on strategic issues related to national security and white-collar criminal investigations. Preceding David's tenure at the DOJ, he was an Assistant District Attorney for the Philadelphia District Attorney's Office.
David has extensive experience collaborating with US and foreign regulators on multijurisdictional investigations, including OFAC, FinCEN, the US Department of Commerce's Bureau of Industry and Security (BIS), the US Department of State's Directorate of Defense Trade Controls (DDTC), and the UK National Crime Agency (NCA).
David is well versed in matters involving questions under the International Emergency Economic Powers Act (IEEPA), the Export Control Reform Act (ECRA), the Arms Export Control Act (AECA), the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), the Foreign Agents Registration Act (FARA), the Foreign Corrupt Practices Act (FCPA), and the Classified Information Procedures Act (CIPA), among others.
Experience
- Successfully represented an international technology company in its voluntary self-disclosure (VSD) to OFAC resulting in a no-action letter.
- Representing a global technology corporation in a DOJ investigation regarding alleged export control, sanctions, and money laundering violations.
- Representing a US cybersecurity company in responding to inquiries from a US export control regulator.
- Representing a US multinational company in connection with a BIS administrative enforcement proceeding.
- Representing a non-US financial institution in international sanctions and money laundering review and assessment, and implementation of enhanced sanctions and anti-money laundering (AML) compliance policies and procedures.
- Advising a multinational conglomerate on compliance with US sanctions, including preparation of application for an OFAC specific license.
- Advising a leading non-US commodities trading company in its compliance with US sanctions, including with respect to Russia.
- Advising multiple US and international companies regarding impact of conducting business with entities on the US Commerce Department's Entity List.
- Advising multiple companies on the implications of DOJ's Data Security Program on their operations.
- Advised a sovereign government on sanctions issues related to the establishment of a national investment fund.
- United States v. Huawei Tech. Co., Ltd., et al.: Ongoing criminal investigation into a Chinese telecommunications conglomerate for violating US economic sanctions and efforts to misappropriate US intellectual property, including trade secret information and copyrighted works*
- United States v. Soong: Criminal prosecution of an individual for the unlawful export of sensitive aeronautics software to an entity on the US Commerce Department's Entity List, resulting in a guilty plea and a denial of export privileges*
- United States v. Airbus SE: Multinational investigation into violations of the FCPA, AECA and ITAR, resulting in the largest global foreign bribery resolution at the time and a Consent Agreement with DDTC*
- United States v. All Petroleum-Prod. Cargo Aboard the Bella, et al.: Successful civil forfeiture action resulting in the forfeiture of more than one million barrels of sanctioned Iranian petroleum product*
*Matters prior to joining White & Case
Next Generation Partner, The Legal 500: International Trade: National Security (2025)
Department of Justice's John Marshall Award for Asset Forfeiture (2023)
National Security Division Assistant Attorney General's Award for Outstanding New Initiative (2023)
Criminal Division Assistant Attorney General's Award (2021)
National Security Division Assistant Attorney General's Award for Excellence (2021)
Office of the Director of National Intelligence - Meritorious Unit Citation (2020)
"Tackling the Global Shadow Fleet Behind Sanctioned Oil Flows," Atlantic Council, Washington, DC, February 2, 2026 (Panelist)
"National Security Risks and Compliance," Global Investigations Review (GIR) Live, Washington, DC, November 13, 2025 (Co-Chair)
"The USG's Focus on Cartels and Transnational Criminal Organizations (TCOs) and the Interplay with Sanctions Enforcement," ACI New York Forum on Economic Sanctions, New York, NY, December 3, 2025 (Moderator)
"Export Controls, Sanctions, and Investment Controls," Washington International Trade Association (WITA) Academy Intensive Trade Seminar, October 6, 2025 (Panelist)
"The Life of a Legal and Compliance Professional in 2025: The 'Behind the Scenes' of the Job Amid New Priorities, Pressures, Economic and Geopolitical Shifts," ACI Global Anti-Corruption, Ethics & Compliance Conference, New York, NY, June 11, 2025 (Panelist)
"Regulatory and Enforcement Panel: Cross-Agency Coordination and Priorities," ACI Economic Sanctions Enforcement and Compliance Conference, Washington, DC, May 1, 2025 (Panelist)
"EU & US Sanctions Update: Keeping Track of Evolving Sanctions" and "Navigating the New Frontiers: Sanctions & Export Controls," Economic Crime Prevention DACH, Zurich, Switzerland, March 17, 2025 (Speaker)
"Supplier Circumvention and Your Screening Program: Monitoring Resellers to Mitigate the Risk of Export and Sanctions Violations," ACI Annual Forum on Advanced Global Export Controls, Washington, DC, February 26, 2025 (Panelist)
"Preparing for the Post-Election Aftermath: Repositioning Your Economic Sanctions and Export Compliance Programs for a New Administration," ACI New York Forum on Economic Sanctions, New York, NY, December 4, 2024 (Panelist)
"Sanctions & AML Meeting," Global Investigations Review (GIR) Live, Washington, DC, November 14, 2024 (Conference Co-Chair)
"The Middle East and the Sanctions Compliance Intricacies: Hypothetical Scenarios on Navigating Complex Compliance Issues," C5 London Forum on Global Economic Sanctions, London, UK, November 6, 2024 (Panelist)
"Export Controls and Sanctions," Washington International Trade Association (WITA) Intensive Trade Seminar (Virtual), September 27, 2024 (Speaker)
"Enforcement, Asset Seizures and Penalties: Cross-Agency Priorities, Coordination and Trends," ACI Economic Sanctions Enforcement and Compliance Conference, Washington, DC, April 30, 2024 (Panelist)
"Keeping Up with Russian Sanctions: Key Developments and Russia Sanctions Impacting the Insurance Industry," ACI 14th Annual AML & OFAC Compliance Forum for the Insurance Industry, New York, NY, February 13, 2024 (Panelist)
"Combatting Kleptocracy – International Experiences," Royal United Services Institute (RUSI) Serious and Organised Crime Conference, London, UK, December 4, 2023 (Speaker)
"DOJ's White Collar Enforcement Priorities," American Bar Association Criminal Justice Section Fall Institute, Washington, DC, November 2, 2023 (Speaker)
"Enforcement Landscape Update," Society for International Affairs Fall Advanced Conference, Washington, DC, October 23, 2023 (Panelist)
"Latest Developments in US Enforcement and Steps Toward Global Cooperation," Association of Certified Sanctions Specialists, New York, NY, October 13, 2023 (Panelist)
"Building Common Ground: Transatlantic Approaches to Economic Statecraft," Atlantic Council & Atlantik-Brücke Transatlantic Forum on Geoeconomics, Berlin, Germany, September 22, 2023 (Speaker)
"Proliferation Financing: Countering the Evasion of Sanctions and Export Controls," The Consortium, LLC Academy of Learning, Washington, DC, September 7, 2023 (Speaker)
National Foreign Trade Council, Washington, DC, June 28, 2023 (Speaker)
Forum on Sanctions and AML Compliance, Cambridge Forums, Leesburg, VA, June 14, 2023 (Speaker)
"Combatting Illicit Diversion," Semiconductor Industry Association Spring Export Control Conference, Washington, DC, June 7, 2023 (Speaker)
"Considerations When Operating in an Evolving Geopolitical Environment," Compliance Week National, Washington, DC, May 16, 2023 (Speaker)
"In Hot Pursuit of Sanctions Evaders: Cracking Down on Russia's Global Network," Atlantic Council, Washington, DC, May 18, 2023 (Speaker)
"USG Joint Enforcement and Compliance Activities," Society for International Affairs Spring Conference (Virtual), May 9, 2023 (Speaker)
"DOJ's New FCPA: Sanctions and Export Control Enforcement," Boston Bar Association White Collar Crime Conference, Boston, MA, May 4, 2023 (Speaker)
"The Disruptive Technology Strike Force: A New Era in Export Enforcement," MA Small Business Development Center Network, Boston, MA, April 28, 2023 (Speaker)
Georgetown University Law Center, Washington, DC, April 11, 2023 (Guest Lecturer)
"Russia – Sanctions, Kleptocracy, Illicit Finance," UK-US Public-Private Banking Dialogue on Illicit Finance (Virtual), February 27, 2023 (Speaker)
National Council on International Trade Development, Washington, DC, January 11, 2023 (Speaker)
"The Enforcement Environment: Perspectives from the Authorities," Practising Law Institute Coping with US Export Controls and Sanctions, Washington, DC, December 16, 2022 (Speaker)
"Starving the Kleptocratic Kremlin to Rebuild Ukraine," International Anti-Corruption Conference, Washington, DC, December 9, 2022 (Speaker)
