Daniel S. Kahn
Former senior DOJ official with more than a decade of experience in criminal and regulatory investigations. Headed DOJ’s Fraud Section and FCPA Unit.
Dan represents companies and individuals in government enforcement matters, conducting internal investigations and in compliance matters. Dan served for 11 years in senior roles at the Department of Justice.
The Wall Street Journal described Dan as DOJ’s “most recognizable expert on the Foreign Corrupt Practices Act.” At DOJ, Dan was acting Deputy Assistant Attorney General of the Criminal Division and Chief of the Fraud Section, and Chief of the FCPA Unit. He supervised matters involving the FCPA, money laundering, and digital currency, commodities, securities, healthcare and procurement fraud.
At DOJ, Dan played a central role in developing enforcement policies on the FCPA, corporate enforcement, compliance and monitors. He worked with authorities around the world, and tried a number of cases to verdict.
Dan co-authored a treatise on corporate criminal investigations, and teaches Corporate Criminal Investigations at Harvard Law School and Global Anti-Corruption at Georgetown Law Center.
Experience highlights
- Serving as a testifying anti-corruption expert witness for a multinational energy company in connection with an arbitration against a Latin American government
- Successfully represented a global fiber optic cable company in an FCPA matter with DOJ involving demands for potentially improper payments in Southeast Asia
- A global defense company in an FCPA investigation by DOJ and SEC
- A publicly traded mining company in connection with a securities fraud and insider trading investigation
- A multinational defense company in connection with an FCPA investigation
- A publicly traded company in connection with an investigation into short-selling and manipulative trading
- A publicly traded healthcare company in connection with a DOJ investigation into potential Anti-Kickback Statute violations
- A multinational publicly traded technology company in connection with potential FCPA violations and fraud
- A special committee of the board of a publicly traded telecommunications company concerning potential governance issues and fraud by management
- The board of a public international organization concerning allegations of misconduct by a senior executive
- A multinational chemical company in an internal investigation of potential fraud and corruption
- A global financial institution in investigations by multiple U.S. regulators for potential anti-money laundering violations
- A global consulting firm in connection with potential FCPA violations
- A multinational company in an internal investigation of third-party practices in Asia
- A corporate executive in connection with an antitrust investigation
- A consumer products company in connection with an internal investigation into accounting issues
- A multinational communications company for compliance and data management issues
- A global financial institution in connection with consent order by the Fed
- A global communications company in an internal investigation into allegations related to governance and revenue recognition issues
Insights
News
Credentials
Recognition
CFTC Chairman’s Award for Regulatory Excellence, 2020
FBI Outstanding Service Award, 2019
Assistant Attorney General’s Award for Exceptional Service, 2017 and 2015
Assistant Attorney General’s Award for Distinguished Service, 2012
Chambers USA – FCPA
Education
- cum laude
- summa cum laude
Professional history
- Partner, Davis Polk, 2021-present
- Acting Deputy Assistant Attorney General, Criminal Division, U.S. Department of Justice, 2021
- Acting Chief, Fraud Section, U.S. Department of Justice, 2020-2021
- Senior Deputy Chief, Fraud Section, U.S. Department of Justice, 2019-2020
- Chief, Foreign Corrupt Practices Act Unit, U.S. Department of Justice, 2016-2019
- Assistant Chief, Foreign Corrupt Practices Act Unit, U.S. Department of Justice, 2013-2016
- Trial Attorney, Fraud Section, U.S. Department of Justice, 2010-2013
- Davis Polk, 2003-2010
Qualifications and admissions
- District of Columbia
- State of New York