John B. Reynolds, III
  1. Partner

Mr. Reynolds is a partner in Davis Polk’s Financial Institutions Group and he heads the firm's economic sanctions and national security practice. He practices in the firm’s Washington DC office, where he advises U.S. and international clients on trade, security and regulatory issues. He frequently represents clients before the U.S. Departments of State, Treasury, Commerce, Defense and Homeland Security. With over 25 years of experience in export controls and economic sanctions and CFIUS reviews, he counsels across industry sectors concerning all types of international compliance and enforcement issues, especially matters involving U.S. national security.

Mr. Reynolds is regularly rated in the nation’s top tier of international trade lawyers by Chambers USA, which acknowledges him as a “highly respected” Committee on Foreign Investment in the United States (CFIUS) practitioner, noting that “he is perfectly placed to provide high-level advice to the financial institutions that increasingly come knocking on his door when in need of compliance expertise,” and commending him as “diplomatic and savvy when dealing with governments in tense situations and creative in how he analyzes problems.”

Work Highlights

  • Manages international investment transactions, acquisitions, joint ventures and privatizations
  • Counsels clients on inward and outward foreign investment transactions (particularly those that include a national security component), economic sanctions, anti-money laundering, export controls, anti-boycott compliance and compliance with the Foreign Corrupt Practices Act (FCPA)
  • Advises on foreign acquisitions of U.S. defense and critical infrastructure companies, including negotiating facility security clearances and FOCI mitigation agreements with the Defense Counterintelligence and Security Agency (DCSA)
  • Provides the full range of economic sanctions and anti-money laundering services, including policy advice, risk assessments, transaction counseling, compliance programs, licensing, and defense of enforcement actions before the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN)


Mr. Reynolds has been recognized as a leading lawyer in various industry publications:

  • Chambers USA  International Trade: Export Controls and Economic Sanctions: Nationwide, Band 1
  • Chambers USA  International Trade: CFIUS Expert: Nationwide
  • Chambers noted Mr. Reynolds’ “rare combination of transactional and regulatory acumen [that] distinguishes him in the marketplace” and said that he was “equally comfortable whether dealing with Wall Street investment banks or branches of government.” He was hailed as “an outstanding OFAC practitioner who has worked in the field for years and therefore has a tremendous sense of how it has evolved.” Chambers named Mr. Reynolds "first choice for referrals relating to OFAC."
  • Consistently named by Chambers Global as one of the “Leaders in Their Field” for his CFIUS experience and ranked in its top tier of Leading Lawyers for his work in export controls and economic sanctions and privacy and data security; clients describe him as “bright, strong and thoughtful” 
  • Best Lawyers in America  International Trade and Finance Law
  • Included in the Guide to the World’s Leading International Trade Lawyers 
  • Law360 – “International Trade MVP,” 2013

Of Note

  • American Bar Association
    • Steering Committee (2008-present), Chair (2001-2003) and Vice Chair (1997-2000), Committee on Export Controls and Economic Sanctions
    • Co-Chair, Committee on Senior International Appointments (1996-1997)
    • Co-Chair (1992-1996) and Vice Chair (1991-1992), Committee on National Security

Professional History

  • Partner, Davis Polk, 2012-present
  • Partner, Wiley Rein, 1996-2012
  • Counsel, Debevoise & Plimpton, 1994-1996
  • Attorney-Adviser, Office of the Legal Adviser, U.S. Department of State, 1982-1988
  • Law Clerk, Hon. Caleb M. Wright, U.S. District Court, Delaware, 1981-1982

Bar Admissions

  • District of Columbia
  • State of New York


  • B.A., Biology and Political Science, Williams College, 1978
    • magna cum laude
  • J.D., Yale Law School, 1981
    • Articles and Topics Editor, Yale Journal of World Public Order