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.
- 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.
- Co-author, “FCPA Corporate Enforcement Policy: Pilot Program Redux,” Law360 (March 1, 2018)
- Quoted, “Wal-Mart FCPA Settlement Offers Big Lessons for GCs About Bribery,” Corporate Counsel (November 17, 2017)
- Quoted, “How Wal-Mart Avoided a Record Fine but Still Paid Dearly,” Corporate Counsel (November 16, 2017)
- Quoted, “Nigeria, China Riskiest For IP, Ropes & Gray Survey Says,” Law360 (September 21, 2017)
- Quoted, “The Meaning of Declinations Obtained by IBM, MTS, Net1, Newmont Mining and Vantage,” The Anti-Corruption Report (September 6, 2017)
- Quoted, “U.S. Uses Rare Tactic in Latest Bribery Case: a Sting,” The Wall Street Journal, Risk & Compliance Journal (August 31, 2017)
- Quoted, “DOJ Reiterates Commitment to FCPA Enforcement but Resources May Become an Issue,” The Anti-Corruption Report (July 19, 2017)
- Quoted, “Distilling lessons from the FCPA Pilot Program,” Compliance Week (July 5, 2017)
- Quoted, “DOJ's FCPA Pilot Program Wins Some White-Collar Praise, to a Point,” Corporate Counsel (April 14, 2017)
- Co-author, “Evaluating FCPA Pilot Program: The Data, The Trends,” Law360 (April 13, 2017)
- Co-author, “What new DOJ guidance means for compliance,” Compliance Reporter (April 11, 2017)
- Quoted, “Managing Subsidiary Risks: Setting Things Up for Success,” The FCPA Report (March 29, 2017)
- Co-author, “DOJ’s New Guidance for Compliance Programs,” Harvard Law School Forum on Corporate Governance and Financial Regulation (March 19, 2017)
- Co-author, “To Certify or Not to Certify: Considerations for Whether to Certify Compliance With the Anti-Bribery Standard ISO 37001” The FCPA Report (March 15, 2017)
- Quoted, “White-collar practitioners anticipate new push to amend the FCPA in 2017,” Global Investigations Review (January 11, 2017)
- Quoted, “A Close Look at the DOJ’s New Declination Plus Disgorgement Settlement Approach,” The FCPA Report (October 12, 2016)
- Quoted, “Declinations becoming ‘NPA-lite’ under FCPA pilot programme, lawyers say,” Global Investigations Review (October 4, 2016)
- Quoted, “Yates Memo Driving Wedge Between Companies And Workers,” Law360 (July 20, 2016)
- Co-author, “The Pilot Program in Practice: A Comparison of Pre- and Post-Program Resolutions,” The FCPA Report (July 13, 2016)
- Quoted, “How Nortek and Akamai Escaped SEC and DOJ Prosecution for Chinese Bribery,”The FCPA Report (June 15, 2016)
- Quoted, “What the Panama Papers means for FCPA investigations,” Global Investigations Review (June 2, 2016)
- Co-author, “No FCPA jurisdiction based solely on conspiracy and accomplice liability, court rules,” The FCPA Blog (April 22, 2016)
- Co-author, “VimpelCom Highlights Evolving Anti-Corruption Approach,” Law360 (March 10, 2016)
- Quoted, “Canadian Health Science Company and Employee Settle Civil FCPA Charges in Failed Quest for Drug Distribution in Russia,” The FCPA Report (March 9, 2016)
- Quoted, “Five Stages of Corruption and Myriad Internal Controls Failures: Compliance Takeaways From the VimpelCom Settlement,” The FCPA Report (March 9, 2016)
- Co-author, “PTC Inc. Reaches $28M Settlement with DOJ and SEC to Resolve China FCPA Allegations,” LexisNexis (March 4, 2016)
- Quoted, “Compliance lessons from VimpelCom,” Compliance Week (March 1, 2016) (Subscription Required)
- Quoted, “VimpelCom Settlement Highlights U.S. Government’s New Holistic Approach to Anti-Corruption Enforcement,” The FCPA Report (February 24, 2016)
- Author, “Strategies for Combating White Collar Criminal Activity Here and Abroad,” Chapter, Inside the Minds: Managing White Collar Legal Issues. (Thomson Reuters / Aspatore) (2016)
- Quoted, “SFO’s foreign new bribery fining policy is ‘perplexing’,” Global Investigations Review (December 11, 2015)
- Quoted, “New DOJ Metrics for an ‘Effective’ Compliance Program Can Aid in Defining Regulatory, Criminal Infractions, but Carry Implementation Changes,” Association of Certified Financial Crime Specialists (November 12, 2015)
- Quoted, “Korean Companies Active in Global Financial Markets Are Not Prepared for FCPA,” Dong-A Ilbo (June 18, 2015)
- Co-author, “DOJ Is Trying To Show Benefits Of Corporate Cooperation,” Law360 (May 20, 2015)
- Co-author, “The DOJ Sends Strong Messages Regarding Corporate Cooperation in Criminal Matters,” Ropes & Gray Alert (April 27, 2015)
- Co-author, “Duperval And DOJ’s Expansive Approach To Foreign Bribery,” Law360 (April 2, 2015)
- Author, “Recent Developments in Foreign and Domestic Criminal Commercial Bribery Laws,” University of Chicago Law School Legal Forum (2012)
- Co-author, “The Criminal Law Edit, Alignment and Reform (CLEAR) Initiative,” Illinois State Bar Association Journal (2009)
- Speaker, “A New Environment for Anti-Corruption Enforcement and Mergers & Acquisitions in Brazil,” Sister Advogados, Ropes & Gray, and Irell & Manella joint seminar on current trends in anti-corruption enforcement and the economic and political impact in Brazil (November 14, 2017
- Speaker, “Anti-Corruption Enforcement Trends & Best Practices for Navigating Compliance Implementation Challenges: Tailored Advice for the Food & Beverage Counsel,” The 5th Annual FoodBev Exchange (October 4, 2017)
- Speaker, “Legal Risk Management Forum: Mitigating Risk Across Industries and Jurisdictions,” Financial Times and Ropes & Gray joint seminar on managing risk across an organization and risk mitigation best practices (September 14, 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)