Looking at Death Spectre's Lifesap Special Attack I was wondering if he can use it if he is not wounded? There is nothing to say he can't so I assume he can. It just seems to be a VERY powerful ability. This isn't a complaint, merely an observation.

In both the old and new rules the Death Spectre can use Lifesap at any time when it would be legal for him to use a special attack. Whether he is wounded or not makes no difference.

And yes, in both old and new rules the Death Spectre is very powerful