Ryan Rohlfsen

Partner

rohlfsen-ryan
  • JD, Order of the Coif and Order of the Barristers, Drake Law School, 1999
  • BA, Drake University, 1996; Phi Beta Kappa

Qualifications

  • Illinois, 2001
  • Burton Awards “Law360 Distinguished Legal Writing Award” (2017)
  • The Legal 500 Latin America (2016)

Ryan Rohlfsen

Partner

Ryan is a partner in Ropes & Gray’s government enforcement practice and a former U.S. federal prosecutor. He has been representing companies and individuals from around the world in white collar, civil litigation, and international risk areas for almost two decades. Ryan has successfully litigated civil and criminal cases through trials and appeals, and conducted internal investigations on six continents. Ryan also counsels companies in developing world-class compliance programs in anti-corruption, export control and sanctions, international risk management, and data privacy and cybersecurity. Quoting clients, one leading legal industry publication recently noted that Ryan is “very responsive, knowledgeable and energetic – a brilliant lawyer who understands deeply the issues that matter most.”

Prior to joining Ropes & Gray, Ryan was a Senior Trial Attorney with the U.S. Department of Justice’s Criminal Division – Fraud Section in Washington, D.C. and Chicago. At the DOJ, Ryan was part of a small group of federal prosecutors in the U.S. Foreign Corrupt Practices Act (FCPA) Enforcement Unit, the DOJ component exclusively responsible for global enforcement of the FCPA. He successfully led numerous investigations into alleged criminal violations of the FCPA by major corporations and individuals. He also prosecuted cases involving investment fraud, bank fraud, domestic bribery, and other complex white-collar crimes. Ryan worked extensively with foreign and domestic law enforcement – including the Federal Bureau of Investigation, the Internal Revenue Service’s Criminal Investigations Division, and various state attorneys general – as well as the State Department and other agencies. He also worked with civil regulators including the U.S. Securities and Exchange Commission, federal inspectors general, FINRA, and multilateral development banks such as the World Bank.

Before the DOJ, Ryan practiced with another global law firm in its U.S. and European offices. There, he represented companies and individuals in international white-collar matters and complex business and securities litigation.

Ryan regularly presents at major industry conferences, is quoted frequently in the press for expert commentary on white-collar issues, and has written a number of articles for well-known publications, including Law360, The Anti-Corruption Report, Corporate Counsel, and Harvard Law School Forum. Ryan was featured last year on the television show American Greed, in an episode about his prosecution (and successful conviction by jury) of a financial fraudster who turned violent. In 2017, Ryan received the Burton Award for “Distinguished Legal Writing” by Law360.

Experience

  • Represented Akamai Technologies, Inc. in an FCPA investigation by the DOJ and SEC related to certain conduct in China.  Obtained the first declination from the DOJ under the FCPA Unit’s Pilot Program, and a no-fine NPA from the SEC.
  • Represented Zimmer-Biomet in its FCPA resolution with the DOJ and, leading up to the resolution, conducted investigations for the company in a number of jurisdictions.
  • Counseling a global agricultural company on anti-corruption, ethics, and securities law compliance.
  • Counseling a publicly-traded international food and beverage company on development of an ethics and compliance program, and conducting investigations into related matters for the company.
  • Representing an individual executive in connection with an international corruption investigation by the DOJ.
  • Actively advising a number of clients on anti-corruption, trade sanctions, and export control due diligence in connection with joint ventures, mergers, acquisitions, and other key business partner relationships around the world. Industries include life sciences, finance, private equity, technology, telecommunications, energy, food and beverage, and agri-business.  
  • Representing an engineering and construction firm in an internal white-collar corporate investigation in South America.
  • Representing a life sciences company in enhancing its global compliance program, including developing a data-driven risk assessment, enhanced training modules, and new policies and procedures.
  • Coordinating and conducting a global post-acquisition corruption and ethics diligence review and forward risk mitigation plan for a life sciences company.
  • Counseling a life sciences company on a global anti-corruption and ethics risk assessment.
  • Representing an individual executive relating to a major international fraud investigation by the DOJ.
  • Advising a privately held manufacturer of B2B products regarding internal international investigations of alleged fraud, corruption, and other issues.  Also assisting the company on an ongoing basis in the development and implementation of its global ethics and compliance program.
  • Represented a life sciences company in internal investigations into alleged corruption, fraud, and related matters, in Mexico, Brazil, Portugal, India, and South Korea.
  • Counseled a life sciences company on the development of its compliance and ethics program, and conducted proactive risk assessments in Latin America, Asia, and Europe.
  • Counseled a life sciences company under investigation by the World Bank for conduct in Asia.
  • Represented a publicly-traded medical device manufacturer in a global internal investigation, as well as parallel SEC and DOJ inquires, into corruption-related matters in Latin America, Europe, and Asia.  Also represented the company in an unrelated SEC investigation into alleged revenue recognition issues, which was ultimately declined by the agency.
  • Represented an automobile manufacturer relating to alleged corruption and fraud in its global operations.
  • Advised a media company related to alleged corruption and securities law violations in Europe and the Middle East.
  • Conducted proactive risk assessments for a global pharmaceutical company.
  • Represented a pharmaceutical company in an investigation into alleged corruption in Africa and the Middle East.
  • Represented Bank of America in two putative national class-actions, both of which were ultimately dismissed.
  • Defended Merrill Lynch in alleged $100 million dollar commercial litigation arising from corporate tax shelters.
  • Counseled Ameriprise in significant regulatory investigations conducted by the SEC and FINRA.
  • Led litigation team for a manufacturing company during its corporate reorganization, and an international creditor seeking to assert its rights in another corporate restructuring.
  • Represented the University of Chicago and Argonne National Laboratory in a retaliatory discharge trial.
  • Undertaken pro bono representations of federal criminal defendants, and filed a civil plaintiff’s suit on behalf of a fraud victim.
  • As a U.S. federal prosecutor, conducted numerous global investigations into possible FCPA violations and related crimes by several major international companies and individuals.  This included a major U.S. technology company for violations of the FCPA, resulting in a corporate guilty plea and over $100 million in combined criminal and civil penalties and fines. Also led an international investigation into a bribes paid to senior Panamanian government officials to obtain technology contracts, leading to a guilty plea by a global technology company’s senior executive responsible for Latin America.  
  • Also while at the DOJ, conducted review into alleged “robo-signing” practices in the mortgage industry. The investigation was profiled on 60 Minutes and resulted in guilty plea by a key executive for fraud-related charges. Also negotiated a $35 million fine with publicly-traded parent company.

Publications

Presentations

  • Speaker, “Anti-Corruption Enforcement Trends & Best Practices for Navigating Compliance Implementation Challenges: Tailored Advice for the Food & Beverage Counsel,” The 5th Annual FoodBev Exchange (Oct. 4, 2017)
  • Panelist, “Update on the Latest US FCPA Investigations and Changing Landscapes of Global Cooperation,” IBA Asia Pacific Regional Forum on Anti-Corruption Compliance and Enforcement, Seoul (November, 2016)
  • Featured, “A Mother's Costly Revenge," CNBC’s American Greed, Episode 3, Season 10, (April 21, 2016)
  • Speaker, “Transaction Governance”, Transaction Advisors Midwest Symposium, Chicago (September 2015) 
  • Speaker, “Current State of U.S. FCPA and Global Anti-Corruption Enforcement,” Shin & Kim and Ropes & Gray Joint Seminar on Anti-corruption Risks Relating to Korean Companies’ Overseas Business Activities and Strategies to Combat Such Risks, Seoul (June 2015)
  • Panelist, “Emerging Issues: FCPA Voluntary Disclosure,” Live Webcast, The Knowledge Group (May 2015)
  • Panelist, “Cross Border Transactions,” Thomson Reuters 3rd Annual Midwestern M&A and Private Equity Forum, Chicago (May 2015)
  • Host, “Best Practices in Anti-corruption and Compliance,” Roundtable Discussion, Washington D.C. (May 2015)
  • Speaker, “Trends in FCPA Enforcement,” Chicago Law Bulletin FCPA Forum, Chicago, Illinois (April 2015)
  • Panelist, “Corporate Social Responsibility: Risk Becomes Reality,” Supply Chain and Corporate Social Responsibility Seminar, University of Chicago Law School Corporate Lab and ABA Criminal Justice Section Global Anticorruption Committee, Chicago, Illinois (September 2014)
  • Panelist, “Meeting DOJ Expectations: Your Company’s To-Do List,” Chicago Law Bulletin White Collar Crime and Corporate Governance Seminar, Chicago, Illinois (April 2014)
  • Presenter, “Foreign and Domestic Criminal Commercial Bribery,” Combatting Corruption Seminar, University of Chicago Law School Legal Forum and ABA Global Anticorruption Task Force, Chicago, Illinois (November 2011)