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
- Successfully represented a global fiber optic cable company in an FCPA matter with DOJ involving demands for potentially improper payments in Southeast Asia
- Successfully represented a global defense company in an FCPA investigation by DOJ
- A publicly traded mining company in connection with a securities fraud and insider trading DOJ and SEC investigation
- A publicly traded multinational defense contractor in connection with a DOJ investigation into potential False Claims Act violations
- A publicly traded healthcare company in connection with a DOJ civil and criminal investigation into potential Anti-Kickback Statute and False Claims Act violations
- A publicly traded company in connection with a DOJ investigation into short-selling and manipulative trading
- 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
- The board of a multinational company in Asia in connection with allegations of misconduct against senior executives
- A multinational publicly traded technology company in connection with potential FCPA violations and fraud
- 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
- Served as a testifying anti-corruption expert witness for a multinational energy company in an arbitration against a Latin American government
- A corporate executive in connection with an antitrust investigation
- A corporate executive in a healthcare fraud investigation
- A corporate executive in connection with a DOJ and SEC investigation into potential FCPA violations
- A consumer products company in 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