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Ryan Fayhee

Partner

Washington, D.C.

+1 (202) 721-4691

ryan.fayhee@hugheshubbard.com
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Biography
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Ryan Fayhee leads the Sanctions, Export Controls & Anti-Money Laundering practice group at Hughes Hubbard and is a former senior prosecutor and national security official with the U.S. Department of Justice (DOJ).  Ryan’s practice focuses on government and congressional investigations, crisis management, cross-border compliance, corporate governance, and white-collar criminal defense.

Ryan draws upon a multi-disciplinary skillset to assist corporations, boards of directors, audit committees, and senior executives facing high-profile reputational risks and incident response, often involving U.S. and foreign regulators and enforcement authorities, political stakeholders, and the media.  He also advises clients on strategic opportunities, governance and compliance best practices, acquisition due diligence, and national security reviews before the Committee on Foreign Investment in the United States (CFIUS).

An experienced trial lawyer, Ryan has successfully tried several cases to verdict, with the unique ability to handle deeply regulatory matters and seamlessly transition to high profile enforcement actions involving the DOJ as well as regulators at the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC). 

Ryan has been named to Global Investigations Review’s elite list of the most respected sanctions lawyers in Washington, D.C. The Legal 500 has recognized Ryan for “excel[ing] at leading and conducting investigatory work as a result of the ‘wealth of experience and insights’ he gained in his former position as a DOJ national security prosecutor.”

Ryan’s clients come from varied industries, including financial services, private equity, technology, aerospace and defense, telecommunications, energy, mining, construction materials, logistics, pharmaceuticals, and consumer goods.

Ryan maintains an active pro bono practice and, in particular, has extensive experience representing current and former hostages of foreign governments and transnational criminal organizations, as well as the unlawfully detained, with a focus on advocating for victim families, securing release, and ensuring long term reintegration.  

Previous Experience

Prior to private practice, Ryan served for 11 years in the DOJ, where he was a leading prosecutor handling complex cross border investigations and prosecutions affecting the national security and foreign policy of the United States, including espionage, sanctions and embargoes, arms proliferation, trade secret theft, cybercrime, corruption, and money laundering. Ryan also served in the National Security Division, where he most recently served as the principal DOJ attorney overseeing sanctions and export control prosecutions nationally.  He also served on the inter-agency staff for CFIUS.

Ryan’s most notable investigations and prosecutions have received prominent national and international media coverage. Several were recognized with the DOJ’s highest awards.  In 2010, Ryan was awarded the Attorney General’s Award for Excellence in Furthering the Interests of U.S. National Security for his role in the prosecution and disruption of a vast international proliferation network responsible for smuggling electrical components from the U.S., which were ultimately used in improvised explosive devices targeting troops in Iraq and Afghanistan. In 2009, Ryan received the Assistant Attorney General Award for Supporting the National Security Mission for his role in the investigation and prosecution of an espionage ring involving corrupt Department of Defense officials. Ryan has received numerous other awards from the DOJ and multiple recognitions from the law enforcement and intelligence communities.

Ryan began his legal career as a federal law clerk in the Central District of Illinois, his home district, prior to being recruited to DOJ through the prestigious Attorney General’s Honors Program, where initially he handled fraud matters arising under the federal False Claims Act.

Selected Matters

  • Represented the board of directors of a multinational company in a high profile internal investigation into allegations of terrorist financing, sanctions, and money laundering activities
  • Represented a multinational technology company in a congressional investigation and subsequent constitutional litigation challenging novel government-wide debarment and suspension actions
  • Represented a multinational luxury goods company in a congressional investigation involving allegations of sanctions violations and related money-laundering activities of third parties
  • Represented a non-U.S. CEO under indictment by DOJ for sanctions violations
  • Represented a global technology company in an internal investigation and OFAC disclosure related to potential sanctions violations
  • Represented a foreign oil and gas company in a DOJ sanctions investigation that resulted in a criminal declination
  • Represented a multinational real estate firm in a Financial Crimes Enforcement Network (FinCEN) investigation involving allegations of kleptocracy and related money laundering activities
  • Represented a major Latin American pharmaceutical company before OFAC in connection with the successful release of several million dollars in blocked funds inadvertently used to pay a supplier in a country subject to U.S. sanctions
  • Represented a Pakistan-based bank in connection with a compliance gap assessment and remediation involving mobile to mobile payment technology
  • Represented a private equity firm in a due diligence investigation related to potential sanctions violations that resulted in the target company making a disclosure to government authorities
  • Represented a U.S. defense contractor in an internal investigation and DDTC disclosure related to cybersecurity and potential export control violations
  • Represented an individual under DOJ investigation for possible violations of the Foreign Agents Registration Act (FARA)
  • Represented a multinational company before CFIUS in connection with its acquisition of a cutting edge technology start-up
  • Prepared cyber and other incident response plans and trained senior executives on cybersecurity best practices, trade secret protections, and trade compliance protocols
  • Advised several multinational financial institutions on trade and sanctions compliance, due diligence protocols and best practices related to screening procedures

Recognitions

  • Recognized as an International Trade & Sanctions “Distinguished Adviser” by Financier Worldwide Magazine (2021)
  • Recognized as one of the 25 most respected sanctions lawyers in Washington, D.C. by Global Investigations Review (2019)
  • Recognized in The Legal 500 United States, Dispute Resolution: International Trade (2019 – 2022)
  • Recognized in The Legal 500 United States, Corporate Investigations and White-Collar Criminal Defense (2019 – 2021)
  • Recognized in Who's Who Legal: Trade & Customs - International Sanctions (2022)
  • 2019 Capital Pro Bono High Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia

Highlighted Publications

  • “The Growing and Continued Focus on Chinese Investment in CFIUS Reviews,” WorldECR (July 2021) (co-authored with Roy Liu and Tyler Grove)
  • “Ransomware Attacks and Responses,” Global Investigations Review, Guide to Cyber Investigations, 2nd Ed. (June 2021) (co-authored with Tyler Grove) 
  • "First Referral to the ECJ to Interpret the Extent of EU Blocking Statute," International Review of Compliance and Business Ethics (October 2020) (co-authored with Olivier Dorgans, Tyler Grove, Paul Charlot, Camille Mayet, and Nicolas Burnichon)
  • "The Art of Compliance: Addressing Anti-Money Laundering and Sanctions Risk Exposure in the Art Market," WorldECR (July 2020) (co-authored with Tyler Grove and Jonathan Zygielbaum)
  • "Buyer Beware: Note to Turkish Companies Doing Business in Iran," Turkish Law Blog (August 2019) (co-authored with Tyler Grove and Rayhan Asat)
  • "Subpoenas Against 3 Banks Boost DOJ's China Initiative," Law360 (July 2019) (co-authored with Ashley Hodges)
  • "The Global Magnitsky Act: Sanctions in Response to International Crises," WorldECR (December 2018) (co-authored with Alan Kashdan, Olivier Dorgans, Tyler Grove, and Clothilde Humbert)
  • "Snapback to the Future: A Case Study of How the U.S. Withdraw from the Iran Nuclear Deal Impacts EU Companies," International Review of Compliance and Business Ethics (October 2018) (co-authored with Tyler Grove and Clothilde Humbert)
  • "Preparing for a Sanctions Crackdown on Apparel Companies with Operations in China," The Anti-Corruption Report (October 2018) (co-authored with Ashley Hodges)
  • "Blockchain Technology and Export Controls," The Export Practitioner (September 2018)
  • "Businesses Face Uncertainty in Sanctions Compliance Obligations After U.S. Withdraw from Iran Nuclear Deal," Financial Executives International (June 2018)

Highlighted Lectures

  • “HHR Client Briefing on Additional U.S./EU Sanctions in Response to the Crisis in Ukraine,” Hughes Hubbard & Reed, webinar, March 17, 2022 
  • “HHR Client Briefing on New U.S./EU Sanctions in Connection with the Crisis in Ukraine,” Hughes Hubbard & Reed, webinar, February 25, 2022
  • “How to Work Effectively with OFAC,” ACI’s 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance, December 8, 2021
  • “Supply Chains: Meeting Increased Due Diligence Expectations and Mitigating Sanctions Risks for Your Supply Chain,” ACI’s 14th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance, April 27, 2021
  • "Mitigating Ransomware Sanctions Risks," Presented by Dow Jones Risk & Compliance and Featuring The Wall Street Journal, webinar, November 18, 2020
  • Speaker, "Known Knowns and Known Unknowns: A Practical Outlook on the Sanctions Landscape," Global Trade Review Nordics 2019 Conference, Stockholm, November 19, 2019 
  • “Risks and Best Practices Concerning U.S.-Mexico Trade and Anti-Corruption Efforts:  Moving Forward During Uncertain Times,” Hughes Hubbard & Reed and Sánchez DeVanny joint event, Mexico City, Mexico, August 28, 2019
  • Panelist, "Evolving Trade Challenges and Financing Priorities," Global Trade Review US 2019 Conference, Chicago, June 13, 2019
  • Speaker, "Mindful Cross Training: Framing an Effective Approach in the Present to Assist Your Institution's Research Compliance Risks for the Future," Health Care Compliance Association 2019 Research Compliance Conference, Orlando, June 12, 2019
  • Panelist, “The Beneficial Ownership Rule: Focus on Shell Companies and Customer Due Diligence,” Practising Law Institute’s Anti-Money Laundering 2019 Conference: Risks, Due Diligence and Compliance in an Evolving Legal and Technological World, San Francisco, June 10, 2019
  • "Third Party Risk Management for Financial Institutions: Best Practices and Effective Tools," The Knowledge Group, webinar, March 12, 2019
  • Speaker, "The Future of Internal Compliance Procedures," C5's 7th Annual Forum on Economic Sanctions & Financial Crime, London, November 15, 2018
  • Moderator, "OFAC and OFSI Share Regulatory Landscape, Compliance Expectations and Enforcement Priorities," C5's 7th Annual Forum on Economic Sanctions & Financial Crime, London, November 14, 2018
  • Moderator, "Government Panel: Enforcement of Sanctions and Regulatory Priorities," Compliance Week Sanctions Risk Management Conference, New York, October 15, 2018
  • “AML/Trade: Practitioner-led Case Study," UC Berkeley Law Compliance Academy, Paris, France, July 25, 2018

Highlighted Matters

  • Represented the board of directors of a multinational company in a high profile internal investigation into allegations of terrorist financing, sanctions, and money laundering activities
  • Represented a multinational technology company in a congressional investigation and subsequent constitutional litigation challenging novel government-wide debarment and suspension actions
  • Represented a multinational luxury goods company in a congressional investigation involving allegations of sanctions violations and related money-laundering activities of third parties
  • Represented a non-U.S. CEO under indictment by DOJ for sanctions violations
  • Represented a global technology company in an internal investigation and OFAC disclosure related to potential sanctions violations
  • Represented a foreign oil and gas company in a DOJ sanctions investigation that resulted in a criminal declination
  • Represented a multinational real estate firm in a Financial Crimes Enforcement Network (FinCEN) investigation involving allegations of kleptocracy and related money laundering activities
  • Represented a Pakistan-based bank in connection with a compliance gap assessment and remediation involving mobile to mobile payment technology
  • Represented a private equity firm in a due diligence investigation related to potential sanctions violations that resulted in the target company making a disclosure to government authorities
  • Represented a U.S. defense contractor in an internal investigation and DDTC disclosure related to cybersecurity and potential export control violations
  • Represented an individual under DOJ investigation for possible violations of the Foreign Agents Registration Act (FARA)
  • Represented a multinational company before CFIUS in connection with its acquisition of a cutting edge technology start-up
  • Prepared cyber and other incident response plans and trained senior executives on cybersecurity best practices, trade secret protections, and trade compliance protocols
  • Advised several multinational financial institutions on trade and sanctions compliance, due diligence protocols and best practices related to screening procedures
New Law Enhances Reward Program for AML and Sanctions Whistleblowers
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DOJ Criminal Division Revises Corporate Enforcement Policy to Further Incentivize Voluntary Self-Disclosure and “Extraordinary” Cooperation
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The U.S. Department of the Treasury Implements Historic Humanitarian Sanctions Exceptions
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CFIUS Issues First-Ever Enforcement and Penalty Guidelines
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Commerce Imposes Sweeping Semiconductor Export Controls on China and Changes to Unverified List Enforcement Policy
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FinCEN Issues New Rule for Beneficial Ownership Reporting
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Cutting Through the Noise: Take-Aways from the DOJ’s Recent Announcements Regarding Corporate Criminal Enforcement
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New CFIUS Executive Order Adds National Security Factors for Evaluating Foreign Investments
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European Commission Unveils Forced Labor Ban Proposal; U.S. Department of Homeland Security Publishes More Details on UFLPA Entity List
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CBP Releases Uyghur Forced Labor Prevention Act Guidance
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U.S. Expands License Requirements for Russia and Belarus to Include All Items on Commerce Control List
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U.S. Intensifies Russia Sanctions in Response to Bucha Charges in Ukraine
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U.S. and EU Announce Subsequent Rounds of Sanctions in Response to Russia’s Ongoing Aggression Against Ukraine
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U.S. and EU Announce Next Rounds of Sanctions in Response to Russia’s Military Aggression Against Ukraine
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U.S. and EU Announce Export Controls for Belarus and Russia, Additional Sanctions Targeting Russia
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U.S. Imposes Additional Sanctions, EU Imposes Second and Third Rounds of Sanctions on Russia for Ukraine Invasion
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U.S. Imposes Second Round of Sanctions on Russia and Belarus for Ukraine Invasion
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U.S. and EU Impose Sanctions in Connection with the Crisis in Ukraine
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FinCEN Proposes Beneficial Ownership Rules to Implement Anti-Money Laundering Act of 2020 and Strengthen Bank Secrecy Act
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L'UE étend les sanctions contre la Biélorussie dans un contexte d’attaque hybride et de répression continue
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EU Expands Sanctions against Belarus Amid Hybrid Attack and Continued Repression
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The New EU Dual-Use Regulation Enters into Force: Overview of the Main Changes
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The Growing and Continued Focus on Chinese Investment in CFIUS Reviews
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Hughes Hubbard Explains the Hidden Risks of Ransomware Payments
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President Biden Announces Major Expansion of Sanctions Targeting Russia
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OFAC Announces Burma Sanctions in Response to Coup
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New Anti-Money Laundering Law Expands Government’s Ability to Gather Financial Information from Private Parties
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BIS Releases Final Rule Creating List of Chinese and Russian “Military End Users”
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Commerce Adds Seventy-Seven Parties to Export Blacklist
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President Trump Issues Executive Order Prohibiting Investments in Certain Chinese Companies
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U.S. Department of the Treasury Highlights Compliance Risks with Ransomware Payments
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New Restrictions on Cuban Travel, Hotels, Cigars, and Rum
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U.S. Department of Commerce Tightens Entity List Restrictions and Adds Huawei Entities
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Hong Kong Sanctions Bill Passes Congress
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First Reference to the European Court of Justice to Interpret the EU Blocking Statute in the Bank Melli Iran v. Telekom Deutschland GmBH Case
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Interprétation de la loi de blocage européenne : première saisine de la Cour de justice de l’Union européenne dans l’affaire Banque Melli Iran c/ Telekom Deutschland GmBH
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CFIUS Proposes Changes to Mandatory Declaration Requirements
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BIS Introduces Significant Restrictions on Huawei
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BIS Introduces Significant Restrictions on U.S. Exports to China, Russia, and Venezuela
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Les effets du COVID-19 sur les mesures de sanctions économiques et de contrôle à l’export
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The Effects of COVID-19 on Sanctions and Export Controls
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Treasury Proposes Filing Fees for CFIUS Voluntary Notices
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Treasury Issues Final CFIUS Rules to Fully Implement FIRRMA
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Trump Administration Imposes Heightened Sanctions on Iran in Response to Missile Strike
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Helms-Burton Lawsuits Targeting Companies Doing Business in Cuba Ramp Up
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DOJ Announces Revised Voluntary Self-Disclosure Program for Willful Export Control and Sanctions Violations
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Commerce Department Issues Proposed Rule Creating Sweeping Review Mechanism to Combat Foreign Influence in U.S. Telecommunications Infrastructure
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New Sanctions and Export Control Laws Target Government of China’s Response to Hong Kong Protests
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DOJ Antitrust Division Focuses on Bid-Rigging by Government Contractors
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Treasury Department Creates Assurance Mechanism for Humanitarian Trade with Iran
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United States Imposes Sanctions on Turkey for Military Action in Syria
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U.S. Government Adds Chinese Governmental and Commercial Organizations to the Entity List
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Treasury Publishes Regulations to Implement FIRRMA & Expand CFIUS Review Authority
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OFAC Gives Red Light to Cuban U-Turn Transactions
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U.S. Issues Second Round of Chemical Weapons Sanctions Against Russia
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U.S. Strengthens Sanctions Targeting the Government of Venezuela
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OFAC Expands Reporting Requirements with Interim Rule
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Commerce Temporarily Eases Trade Restrictions on Huawei
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Trump Administration Issues Dual Orders Targeting Huawei and Economic Espionage
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The U.S. Issues New Iran Secondary Sanctions, Placing Europe in the Cross-Fire
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OFAC Issues Guidance on Sanctions Compliance Programs
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U.S. Ends Sanctions Waivers for Countries Importing Iranian Oil
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State Department Will Allow Suits Against Private Cuban Investors on May 2, 2019
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Early Reactions to U.S. Venezuelan Oil Sanctions
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Trump Administration Weighs Allowing Private Suits Against Foreign Investors in Cuba
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OFAC to Delist Deripaska Companies
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The DOJ’s New “China Initiative” Places Chinese Companies at Risk
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Final Snapback Sanctions Against Iran Take Effect
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New Executive Order Targets Venezuelan Economy and Corrupt Asset Transfers
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FinCEN Warns of New Iranian Efforts to Launder Money Through Banks and Virtual Currencies
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Treasury Publishes Interim Rules to Implement CFIUS Reform
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FinCEN to Focus Enforcement on Virtual Currency Platforms and Emerging Technologies
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President Trump Expected to Sign 2019 National Defense Authorization Act, Initiating Reforms to U.S. Foreign Investment Review and Export Controls
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Trump Administration Issues New Executive Order and Guidance on First Round of Iran Snapback Sanctions
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U.S. Elevates India to Strategic Trade Authorization Tier 1 Status, Easing Future Dual-Use Exports
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New Sanctions Advisory: Risks for Businesses with Supply Chain Links to North Korea
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OFAC Revokes Iran Nuclear Deal General Licenses and Issues Wind-Down Authorizations
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President Trump Issues Executive Order Prohibiting Transactions Involving the Government of Venezuela
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Deputy Attorney General Rosenstein Announces New Policy Discouraging "Piling On"
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U.S. Withdraws from Iran Nuclear Deal, Issues Guidance on "Snapback" Sanctions and Wind-Down Activities
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News

Partner Ryan Fayhee Featured in Financier Worldwide's 'Power Players: International Trade & Sanctions 2022 Distinguished Advisers'
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HHR Attorneys Included in Inaugural Lawdragon 500 Leading Litigators in America Guide
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Firm Highly Recommended by Latin Lawyer
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People
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Hughes Hubbard & Reed expands its Economic Sanctions, Export Controls & Anti‑Money Laundering practice in Paris by welcoming Edouard Gergondet as Counsel
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People
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Hughes Hubbard Strengthens IP Practice with Addition of Leading Litigator Andrew Kopsidas
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Litigation Wrap: Fourth Quarter 2021
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Firm Advises Cantor Fitzgerald SPAC in Business Combination with Rumble
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Firm Named to 2021 Global Investigations Review (GIR) 100
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Partner Ryan Fayhee Recognized in Financier Worldwide's “Power Players: International Trade & Sanctions 2021 Distinguished Advisers”
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Firm Achieves Rare Release of OFAC-blocked Funds for LatAm Client
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HHR Reps Cantor Fitzgerald SPAC in $850M Merger With Satellogic
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Hughes Hubbard Advises on $745M Aircraft Asset-Backed Notes Offering for Blackbird Capital II
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Firm Leads Grab in Going Public Via De-SPACing Merger at $40B Pro-Forma Valuation
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Hughes Hubbard Counsels Wipro in $1.45B Acquisition of British Consultancy Firm
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Firm Guides ANI Pharmaceuticals in Deal to Buy Novitium Pharma
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Partner Ryan Fayhee Featured in Financier Worldwide's 'Power Players: International Trade & Sanctions 2020 Distinguished Advisers'
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Firm Advises Platinum Equity in Nesco’s $1.48B Deal
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Firm Leads Cantor Fitzgerald SPAC in Merger With View
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Firm Advises Wipro in Purchase of Eximius Design
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Firm Assists Infosys in Deal to Buy Blue Acorn iCi
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In WorldECR Magazine: The Art of Compliance: Addressing Anti-Money Laundering and Sanctions Risk Exposure in the Art Market
Articles & Press
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Hughes Hubbard Again Named Among Latin Lawyer 250
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Awards
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Firm Shortlisted for Two Honors in The Deal Awards Middle Market 2020
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Firm Named to 2019 Global Investigations Review (GIR) 100
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Ryan Fayhee Named Among Global Investigations Review's Most Respected Sanctions Lawyers in DC
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People
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In Law360: Subpoenas Against 3 Banks Boost DOJ’s China Initiative
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Roy (Ruoweng) Liu Joins Hughes Hubbard’s Greater China and International Trade Practices
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Hughes Hubbard Advises Wipro in Purchase of Digital Engineering Firm
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​Firm Leads Efforts to Free Ex-Marine Detained in Russia
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Pro Bono
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Firm Guides Daimler in Acquisition of Self-Driving Technology Company Torc Robotics
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In WorldECR Magazine: The Global Magnitsky Act: Sanctions in Response to International Crises
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Hughes Hubbard Selected for Inclusion in the 2018 Global Investigations Review (GIR) 100
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In The Anti‑Corruption Report: Preparing for a Sanctions Crackdown on Apparel Companies With Operations in China
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​Former DOJ National Security Division Official Ryan Fayhee Joins Hughes Hubbard’s International Trade Practice
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People
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Education
  • Georgetown University Law Center, J.D., cum laude
  • Purdue University, B.A.
Bar Admissions
  • District of Columbia
Areas of Focus
Africa
Anti-Corruption & Internal Investigations
Banking & Financial Services
Corporate Governance
Data Privacy & Cybersecurity
Defense Industry
Digital Assets and Blockchain
Environmental, Social & Governance (ESG)
Litigation
Sanctions, Export Controls & Anti-Money Laundering
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