Bryan J. Sillaman is a partner in Hughes Hubbard & Reed’s Anti-Corruption & Internal Investigations practice group, based in the firm’s Paris office.
During his more than 15 years of practice, Bryan has counseled clients across a range of governance and compliance issues, including the development of policies and procedures, extensive due diligence relating to third-parties and joint venture partners, complex internal investigations, proactive internal reviews and audits of their global operations, and navigating the complexities of cross-border monitorships. Bryan’s experience and travels have covered a range of jurisdictions including Angola, Brazil, China, Indonesia, Malaysia, Mozambique, the Middle East, Nigeria, Russia and Venezuela.
In addition to his anti-corruption experience, Bryan advises clients and publishes and speaks regularly on broader ESG-related topics affecting multinational enterprises.
Prior to joining Hughes Hubbard, Bryan was an attorney in the Division of Enforcement of the US Securities and Exchange Commission (SEC) where he earned a Division Director Award.
Previous Experience
Attorney, Division of Enforcement, US Securities and Exchange Commission, 2004 – 2007
Division Director Award (2006)
Highlighted Publications
Co-author, with Alexandra Poe and Andrew Fowler, “How to ESG: A Resource Guide for Establishing an ESG Program for your Company,” Hughes Hubbard (August 2022)
Co-author, with Jan K. Dunin-Wasowicz, "What Constitutes Sustainable Activity? EU Taxonomy Has Compliance Lost in Shades of Green," Corporate Compliance Insights (March 2022)
Co-author, with Alexandra Poe, "Corporate ESG: From Policy to Action," Corporate Counsel (March 2021)
Co-author, with Alexandra Poe, "Five Steps to Establishing a Corporate ESG Policy for the Present Moment," The Anti-Corruption Report (October 2020)
Co-author, with Anne Hukkelaas Gaustad, “How AFA Compliance Program Controls Are Changing the French Anti-Corruption Compliance Landscape,” The Anti-Corruption Report (April 2019)
Co-author, with Marie-Agnès Nicolas, Leon Ioannou, and Bernardo Viana, “How Far Do Your Arms Reach? A Brief Case Study on the Extraterritoriality of Anti-Bribery Laws” International Review of Compliance and Business Ethics (March 2018)
Co-author, with Marie-Agnès Nicolas, “Lessons Learned from the First-Ever French Convention Judiciaire d’Intérêt Public Concluded with HSBC,” The Anti-Corruption Report, Vol. 7, No. 2 (January 2018)
Co-author, with Arnaldo Bernardi, "Italy Steps Up Whistleblowing Regulation," The FCPA Blog (January 2018)
Co-author, with Marc Henry, “Les DPA américains à l’épreuve du droit francais.” (“French Law Puts American DPAs to the Test”). Option Finance/Option Droit & Affaires (May 2016)
Co-author, with Jan K. Dunin-Wasowicz, "French Anti-Corruption Law Reform: A Paper Tiger or a Paradigm Shift?" FCPA Professor (17 May 2016)
Co-author, with Jan K. Dunin-Wasowicz, "Enhancing Foreign Investment Protection Through Anti-Corruption Compliance: A Perspective on Doing Business in Africa," Africa Law Today, Issue 2 (2015)
Panelist, "Transnationalization and the New Frontiers of Compliance," Conference on the Transnationalization of Anti-Corruption Law, Sciences Po, Paris, December 7, 2018
"Compliance Challenges for Oil & Gas: Managing Corruption Risk in Africa," Dow Jones Risk & Compliance, webinar, November 28, 2018
Moderator, "From the Assessment of the Sapin II Law's Anti-Corruption System to the First French Deferred Prosecution Agreement (CJIP),” C5's 6th Conference on Anti-Corruption, Paris, October 16, 2018
"Human Rights Becomes a Legal and Compliance Issue: Practitioner Lecture and Discussion," UC Berkeley Law Compliance Academy, Paris, France, July 26, 2018
Speaker, "Understanding the Impacts of the Sapin II Law," LexisNexis Risk Solutions, webinar, April 17, 2018
Keynote Speaker, Global Investigations Review Live Anti-Corruption Conference, Frankfurt, November 14, 2017
"The DOJ’s FCPA Pilot Program: Exploring Opportunities and Drawbacks," The Knowledge Group LLC, webinar, June 1, 2017
Panel, "Anti-Corruption Reforms and Enforcement in Africa, There is Nowhere to Hide: Accountability is Knocking at Your Door," 2015 Africa Forum, American Bar Association Section of International Law, Nairobi, Kenya, June 4, 2015
Panel discussion on the future of compliance, Ernst & Young's Annual Seminar on Risk & Compliance, London, March 12, 2015
"The FCPA & Beyond," Fifth Annual Anti-Corruption Compliance Strategies in Central and Eastern Europe (CEE), Prague, March 21, 2014
"The Company You Keep: Mitigating Third-Party Risk in Today's Anti-Corruption Environment," Third Annual Business Ethics, Anti-Corruption and Fraud Prevention Strategies in the CEE, South Eastern Europe (SEE) & Commonwealth of Independent States (CIS) Conference, Prague, March 26, 2012
"Overcoming Anti-Corruption Compliance Challenges in the Upstream Oil & Gas Industry: Defining and Executing Systematic, Risk-Based Third-Party Due Diligence," workshop, C5 Fourth Annual Anti-Corruption Conference, Paris, Oct. 21, 2011
Panel, "Anti-Corruption Compliance: Agents, M&A and Joint Ventures," GCM Parker Conferences: Business Ethics Anti-Corruption & Fraud Prevention Strategies in CEE, SEE & CIS, Prague, March 22-23, 2010
Quotes & Interviews
Quoted in "Fifty Shades of Green: How ESG Colors the Future of Legal Work," The Anti-Corruption Report: ACR Brief (August 2022)
Quoted in "Why International Companies Are Integrating the ECCP Into Their Compliance Programs," The Anti-Corruption Report (June 2019)
Quoted in "What SocGen and Legg Mason Say About French and American Enforcement," The Anti-Corruption Report, Vol. 7, No. 14 (July 2018)
Quoted in “SocGen Reaches Historic Deal With France and U.S., Legg Mason Tags Along,” The Anti-Corruption Report, Vol. 7, No. 13 (June 2018)
Highlighted Matters
Current representation of a CAC 40 French multinational engineering and construction company in global review, including with respect to activities in Angola, Brazil, China, Egypt, Ghana, Indonesia, Italy, Kuwait, Malaysia, Nigeria, Russia, Saudi Arabia, Thailand, United Arab Emirates, Venezuela, Vietnam and Yemen
Representation of a venture fund in connection with portfolio holding company activities in Algeria and France
Representation of a Fortune 500 company in connection with FCPA advice regarding business in China
Representation of a New York Stock Exchange (NYSE)-traded company in connection with an FCPA inquiry related to business in Nigeria and other parts of West Africa, including advice in connection with a US Senate inquiry
Representation of a US-based NYSE-traded company in connection with FCPA/Organization for Economic Cooperation and Development (OECD) and related anti-corruption issues, related to business or activities in Indonesia, South Korea, South Africa, Nigeria, Burundi, Rwanda, Uganda, Congo, Cameroon and Saudi Arabia
Successful representation of a Fortune 500 NYSE-traded company in connection with FCPA advice relating to business in Kazakhstan and Azerbaijan
Successful representation of Cenveo Inc. in an internal investigation for an audit committee related to allegations of financial misconduct
Successful representation of an NYSE-traded company in an SEC insider trading investigation
Successful representation of a Big Four accounting firm in connection with a state board of accountancy matter
Successful representation of a board committee of Educate Inc. in merger-related litigation
George Washington University Law School, J.D., 2004, with honors, George Washington Scholar (top 1%-15% of class, as of graduation), Recipient of The Richard L. Teberg Award, Senior Notes Editor, The Public Contract Law Journal, Member, Moot Court Board
