Ryan Rohlfsen


  • JD, Order of the Coif and Order of the Barristers, Drake Law School, 1999
  • BA, Drake University, 1996; Phi Beta Kappa; Study Abroad, The University of Freiberg (Albert-Ludwigs-Universität Freiburg), Freiburg im Breisgau, Germany (1994)


  • Illinois, 2001
  • District of Columbia, 2018

Ryan Rohlfsen


Ryan is a partner in Ropes & Gray’s litigation and enforcement practice group, co-chair of Ropes & Gray’s award-winning global anti-corruption and international risk practice, and a former U.S. federal prosecutor. He represents companies and individuals from around the world in civil and criminal government enforcement matters, internal investigations, and civil litigation. Most recently, he has been advising companies on strategies for preventing or addressing fraud and corruption arising from the economic fallout of the COVID-19 pandemic. 

Ryan has successfully litigated civil and criminal cases through trials and appeals, and conducted investigations on six continents. Ryan also counsels companies in developing world-class compliance programs in anti-corruption, export control and sanctions, international risk management, blockchain and cryptocurrency, 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 on the television show American Greed, in an episode about his prosecution (and successful conviction by jury) of a financial fraudster who turned violent.


  • 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.
  • Conducting an internal investigation in Europe and Asia for a publicly traded, multi-national life sciences company relating to alleged securities fraud and corruption. 
  • Assisting a major pharmaceutical and medical device company in enhancement of its global compliance policies and procedures. 
  • Counseling a global agricultural company on anti-corruption, ethics, and securities law compliance.
  • Representing several individual international executives in the life sciences industry relating to an investigation by the SEC and DOJ into alleged securities fraud, revenue recognition, and corruption issues. 
  • 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.
  • 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.  
  • Counseling an investment advisor relating to an investigation by the SEC for alleged “cherry picking.”
  • Advising a European-based life sciences company in assessing and mitigating its U.S. corruption and regulatory risk. 
  • Represented an individual executive in connection with an international corruption investigation by the DOJ.
  • Represented 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 the DOJ’s international investigation into the auto industry diesel emissions matter.
  • 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.
  • Representing an hospital industry association in response to a DOJ inquiry relating to alleged health care fraud. 
  • 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.



  • Speaker, “Third Party Monitoring (Past, Present, and Future),” Resolution Economics (December 1, 2020)
  • Speaker, “Government Enforcement Roundtable: Priorities, Trends and Considerations for Building a Best in Class Compliance Program for 2021 and Beyond,” Anti-corruption, Anti-bribery, Export Controls & Sanctions (A.C.E.S.) Compliance Summit (November 12, 2020)
  • Speaker, “Predicting the Unpredictable: A Crisis Management Roadmap for Food & Beverage Companies,” FoodBev Exchange (October 9, 2020)
  • Panelist, “Enforcement and Compliance During COVID-19,” Momentum Events Webinar (May 19, 2020)
  • Speaker, “Chief Compliance Officer Roundtable,” The 7th Annual FoodBev Exchange (October 2, 2019) 
  • Speaker, “Triaging Whistleblower Allegations,” First Chair Conference (August 28, 2019) 
  • Speaker, “Leveraging Internal Screening and Healthcare Compliance Resources to Reduce DOJ, SEC and OFAC Penalty Risks,” ACI FCPA & Anti-Corruption for the Life Sciences Industry (June 19, 2019) 
  • Speaker, “International Enforcement Trends: Ensuring Your Compliance Program Stays Ahead of Growing Global Anti-Corruption Efforts,” Anti-corruption, Anti-bribery, Export Controls & Sanctions (A.C.E.S) Compliance Summit (April 2019)  
  • Speaker, “Best Practices for Ensuring Compliance and Minimizing Risk Exposure from International Business Partners and other Third Parties” The 6th Annual FoodBev Exchange (October 16, 2018)
  • Panelist, “Declinations, Aggravating Circumstances and Individual Liability Under the New DOJ Enforcement Policy: Disclosures, Cooperation and Remediation Now Required,” 9th Midwest Anti-Corruption Forum (June 26, 2018)
  • Panelist, “How to Resolve Complex Challenges Around Gifts, Travel & Hospitality and Sponsorship & Congresses,” 12th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry (June 18, 2018)
  • Panelist, “An Offer You Can’t Refuse: Considerations in Multinational Criminal Investigations Involving Privilege and Compelled Testimony Issues,” Thompson Reuters (May 24, 2018)
  • Speaker, “Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs,” Ropes & Gray Podcast (May 17, 2018)
  • Speaker, “Risk Management: Revised FCPA Corporate Enforcement Policy,” Ropes & Gray Podcast (May 7, 2018)
  • Panelist, “International Risks Posed By Digital Currencies,” Ropes & Gray Webinar (April 19, 2018)
  • Keynote, “Cryptocurrency and Blockchain Technology – Implications for Life Sciences and Beyond,” Drake Law School’s Compliance and Risk Management Program Health Law Intensive (April 21, 2018) 
  • Speaker, “Government Roundtable: The ABAC-International Trade Nexus: Focus Enforcement Targets for Enforcement, Cooperation, Coordinated Investigations and Voluntary Disclosure,” Momentum’s 11th annual A.C.E.S. Compliance Summit (April 17 – 18, 2018)
  • 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)
  • JD, Order of the Coif and Order of the Barristers, Drake Law School, 1999
  • BA, Drake University, 1996; Phi Beta Kappa; Study Abroad, The University of Freiberg (Albert-Ludwigs-Universität Freiburg), Freiburg im Breisgau, Germany (1994)
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