Ryan Fayhee leads the Sanctions, Export Controls & Anti-Money Laundering practice group at Hughes Hubbard and is a member of the Anti-Corruption & Internal Investigations practice group. Prior to private practice, Ryan served for 11 years in the Department of Justice, where he was a leading prosecutor handling complex investigations and prosecutions affecting the national security and foreign policy of the United States. He also previously served as the National Export Control Coordinator, the principal Department of Justice attorney overseeing sanctions and export control prosecutions nationally.
Ryan represents companies, boards of directors, audit committees and senior executives in internal and government facing cross-border investigations and advises clients on compliance and acquisition due diligence with a focus on sanctions, export controls, anti-money laundering, anti-corruption, and cybersecurity. Ryan has significant experience assisting multinational companies facing crises and other high profile reputational risks.
Ryan is also an experienced trial lawyer and regularly represents clients in federal court and before the Department of Justice, federal law enforcement authorities, and trade regulators at the Office of Foreign Assets Control (OFAC), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).
"Businesses Face Uncertainty in Sanctions Compliance Obligations After U.S. Withdraw from Iran Nuclear Deal," Financial Executives International (June 2018)
Represented the board of directors of a multinational company in a high profile internal investigation into allegations of sanctions and anti-money laundering violations
Represented a multinational technology company in a congressional investigation and subsequent litigation challenging novel government-wide debarment and suspension actions
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 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 US 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 violation of Foreign Agents Registration Act (FARA)
Represented a non-US CEO under indictment by DOJ for sanctions violations
Advised several multinational financial institutions on trade and sanctions compliance, due diligence protocols and best practices related to screening procedures
Advised several US companies and trained personnel on cybersecurity best practices, trade secret protection, and trade compliance