David PeymanOf Counsel
David advises public and private sector clients on sanctions, AML, FATF evaluations, digital currency regulations and issuances (including CBDCs), government relations, and corporate compliance.
From 2018 to 2020, David served as the Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs. As the State Department's sanctions chief, David led the Office of Economic Sanctions Policy and Implementation and was responsible for managing 25 sanctions programs for the Secretary of State, including Iran, Russia, China, and Venezuela sanctions. David created the State Department's very first economic sanctions targeting team which plays an important role in sanctions implementation and enforcement. David was also instrumental in issuing the first US Global Maritime Sanctions Advisory and facilitated cooperation among flag registries, vessel owners and managers, ports, insurers, and the US government. David built partnerships to combat illicit finance and sanctions evasion that led to greater economic and strategic cooperation with the US for multinational corporations and state-owned enterprises.
Mr. Peyman also led the Office of Threat Finance Countermeasures, which combats terrorist financing, money laundering, and the illicit use of minerals and metals. David's office represented the State Department in the Financial Action Task Force (FATF) and helped devised global digital currency guidance. David's office was also responsible for coordinating US government interagency implementation of the Kimberly Process and he helped create responsible mineral and metal supply chains that considered ESG risk factors.
On April 5, 2020, David was appointed the US Deputy Special Envoy to Combat Antisemitism, with responsibility for Eurasia and Special Projects. Under the US government's initiative to achieve peace between Israel and the neighboring countries, David's portfolio included increasing global economic engagement with Israel.
Before his government service, David led the sanctions compliance framework for the world's largest asset manager and was a federal and state prosecutor and part-time adjunct law professor.
David is a former co-chair of the US State Department Advisory Committee on International Economic Policy, Sanctions Subcommittee.
- Represent second largest maritime flag registry in connection with all aspects of sanctions, compliance, government relations, international trade, and strategic international business growth
- Represent publicly listed commercial bank and asset manager in connection with sanctions and AML compliance, blockchain and digital currency-related matters, and regulatory and business advice in high risk jurisdictions
- Represent large shipping company in connection with sanctions compliance matters
- Created and managed sanctions compliance program for world's largest asset manager
- Advise energy company on sanctions compliance matters
- Advise countries on Anti-Money Laundering and sanctions compliance regulations, and Financial Action Task Force (FATF) evaluations
- Lead State Department division that represented the State Department in the FATF
- Created and lead very first economic sanctions targeting team in the US State Department
- Lead US government delegation to the Kimberly Process (initiative to halt the trade in so-called blood diamonds (rough diamonds sold to finance civil wars) and to protect the legitimate diamond trade)
- J.D., Harvard Law School
- B.A., University of California at Los Angeles
- Mentioned, "Business in China after the blocking statute," FISC Issue 2, July-August 2021
- U.S. Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions, 2018-2020
- Global Lead for Sanctions, BlackRock, 2015-2018
- Special Assistant US Attorney, 2013-2015
- Deputy Attorney General of California, 2011-2015
- Adjust Professor of Law, Southwestern Law School, 2013-2015
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