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, and was on the interagency staff for the Committee on Foreign Investment in the United States (CFIUS).
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).
Highlighted Publications
"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
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 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
