doesn't his aura of fear always work?
and his counterattack can be countered, for example, with pikemen.
For now, it can still be effective, it works ;) But in general, it depends on what you want to use the 4th level for... The Devil is mobile and can quickly take down a hero... But it's not a given that Death won't adapt her tactics, and then the Dragon will be able to, if he wants to!