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 – 2021)
Recognized in The Legal 500 United States, Corporate Investigations and White-Collar Criminal Defense (2019 – 2021)
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

U.S. Expands License Requirements for Russia and Belarus to Include All Items on Commerce Control List

Ryan Fayhee

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