Ryan Rohlfsen co-chairs Ropes & Gray’s global anti-corruption and international risk practice. A former federal prosecutor with the U.S. Department of Justice (DOJ) and former member of the DOJ’s specialized unit responsible for global enforcement of the Foreign Corrupt Practices Act (FCPA), he has been practicing in the area of international government enforcement and compliance risk mitigation for two decades. Ryan is recognized as a leading global anti-corruption and FCPA practitioner.
Ryan represents multinational organizations and senior executives in civil and criminal matters before government authorities and internal investigations. He focuses principally on matters involving allegations of corruption, securities fraud, revenue recognition and accounting fraud, money laundering, sanctions and export controls, and health care fraud, among other issues. Ryan also has deep experience with internal and external whistleblowers, including those represented by counsel seeking a bounty under Dodd-Frank.
Beyond advising companies in crisis, Ryan counsels organizations on the development of cutting-edge corporate compliance programs in the areas of anticorruption and international risk. He also helps companies assess, value and navigate these risks throughout the lifecycle of M&A transactions.
Clients value Ryan’s practical approach, as well as his firsthand knowledge of the prosecutorial mindset. Clients quoted by one leading legal industry publication cite his “really deep mastery of substantive law as well as best practices for companies,” and note that “[h]e can adapt to a changing environment and does this without compromising on quality.” Ryan is also lauded as “incredibly business-savvy,” “pragmatic” and “creative,” with an “unwavering commitment to client service.”
Selected Government-Facing Corporate Investigations
- Currently serve as lead counsel to four publicly traded global life sciences companies with anticorruption matters pending before the U.S. DOJ and SEC. Together, these matters involve dozens of countries spanning every major market in the Americas, Europe, Africa, the Middle East and Asia.
- Successfully guided multiple companies in proactively self-disclosing corporate anticorruption matters to the U.S. and other authorities, all resulting in public or nonpublic declinations. This included a first of its kind corporate self-disclosure in Mexico. For Akamai Technologies, Inc., obtained the first public declination from the DOJ under the FCPA Unit’s Pilot Program, and a no-fine non-prosecution agreement from the SEC.
- Currently advising a global oil services company in a multijurisdictional investigation being conducted by the U.S., Brazilian and U.K. authorities.
- Lead counsel to a U.S.-headquartered global medical device company in its SEC FCPA resolution, including leading the company though an SEC-mandated independent compliance consultant evaluation and related process.
- Advised a Fortune 100 manufacturing company in connection with a DOJ-instigated anticorruption investigation in the Americas, the Middle East and Asia, resulting in no action being taken against the company.
- Lead counsel to a publicly traded chemical company facing an SEC and DOJ inquiry regarding business conduct in Asia. Following an extensive internal investigation, the agencies closed the case without action.
- Counsel to a Special Committee of the Board of a privately held Mexican infrastructure company responding to a DOJ inquiry on a corruption matter.
- Represented a privately held technology company in response to a DOJ anticorruption investigation involving the Americas and the Middle East, resulting in no action being taken against the company or individuals.
- Represented a multinational medical device manufacturer in its FCPA resolution with the DOJ and SEC after conducting investigations for the company in numerous jurisdictions.
- Represented a European publicly traded multinational company in a World Bank investigation.
- Represented a U.S.-based non-profit foundation and its billionaire industrialist benefactor in a corruption and extortion case involving the Russian government.
Selected Internal Corporate Investigations
- Serve as lead anticorruption internal investigations and compliance counsel to numerous global life sciences companies in the pharmaceutical, medical device and biotechnology sectors.
- Retained by the Audit Committee of a Fortune 50 global company to conduct an internal investigation into allegations of impropriety involving complex accounting and financial practices.
- Serve as lead anticorruption counsel to one of the world’s leading aerospace companies, advising on numerous internal investigations and assisting in developing compliance best practices.
- Represent a global retailer in internal anticorruption matters in Asia and the Americas.
- Act as lead counsel to several publicly traded food, beverage and alcohol companies in anticorruption and antifraud investigations, and routinely advise on continual improvement of internal compliance programs for these companies.
- Investigated potential securities fraud and revenue recognition issues involving complex swap and derivative agreements for a global commodities trading firm.
- Represented a Fortune 500 engineering and construction firm in anticorruption and fraud investigations in Latin America and proactive compliance matters.
Individual Executive Representations
- Serve as counsel to a number of high-level corporate executives and affiliated individuals from around the world faced with anticorruption, fraud, money laundering, revenue recognition, environmental, securities fraud and other white-collar investigations by the U.S. DOJ, SEC, CFTC and other agencies.
- Work with local counsel in numerous jurisdictions around the world to carefully coordinate parallel matters.
Proactive Corporate Compliance Advice
- Routinely advise public and private companies on proactive corporate ethics and compliance matters and best practices, including policies, procedures, training and risk assessments.
- Conducted numerous major post-acquisition global risk assessments, including self-disclosure of identified issues.
Experience as a Federal Prosecutor
- Conducted numerous global investigations into possible FCPA violations and related crimes by several major international companies and individuals. This included resolving a matter with major global 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. This work also led to a guilty plea by another global technology company’s senior executive for bribes paid to senior Panamanian government officials to obtain technology contracts.
- Prosecuted fraudulent “robo-signing” practices in the mortgage industry. The investigation was profiled on 60 Minutes and resulted in guilty plea by a key executive to fraud-related charges. Negotiated a $35 million fine with publicly traded company.
- At a jury trial in federal court, successfully prosecuted a former financial advisor for running a Ponzi scheme, which later turned into a murder-for-hire plot. The defendant was later sentenced to 30 years in prison. The case was made into an episode of American Greed.