Ryan Rohlfsen

Ryan’s experience includes representing:

Government-Facing Corporate Investigations

• Publicly traded global companies, particularly in the life sciences industry, in corruption, healthcare and other frauds, money laundering, and related matters pending before the DOJ and US Securities and Exchange Commission (SEC)*
• Numerous publicly traded companies in proactively self-disclosing corporate criminal and civil matters to the DOJ, SEC, and foreign authorities, all resulting in public or nonpublic declinations, including a first-of-its-kind corporate self-disclosure in Mexico, resulting in no action taken*
• Akamai Technologies in obtaining the first public declination from the DOJ under the FCPA Unit’s Pilot Program and a no-fine non-prosecution agreement from the SEC*
• A publicly traded consumer products company facing a state attorney general Make America Healthy Again (MAHA)-related investigation*
• A publicly traded life sciences company in various healthcare fraud-related investigations *
• A global oil services company in a multijurisdictional investigation by US, Brazilian, and UK authorities, resulting in no action in the US or UK against the company*
• A US-headquartered global medical device company in its SEC resolution, including leading the company though an SEC-mandated independent compliance consultant evaluation and related process*
• A Fortune 100 manufacturing company in connection with a DOJ-instigated anticorruption, fraud, and money laundering investigation in the Americas, the Middle East, and Asia, resulting in no action being taken against the company*
• A publicly traded chemical company facing an SEC and DOJ inquiry regarding business conduct in Asia; following an extensive internal investigation, the agencies closed the case without action*
• A special committee of the board of a privately held Mexican infrastructure company in responding to a DOJ inquiry on a US domestic corruption matter*
• A privately held technology company with a DOJ criminal investigation involving the Americas and the Middle East, resulting in no action being taken against the company or affiliated individuals*
• A multinational medical device manufacturer in its FCPA resolution with the DOJ and SEC after conducting investigations for the company in numerous jurisdictions*
• A European publicly traded multinational company in a World Bank investigation*
• A US-based charitable foundation and its billionaire benefactor in a corruption and extortion case in Russia*

Internal Corporate Investigations

• Public and private companies in leading internal investigations, particularly in the life sciences industry, involving corruption, fraud, competition, and related issues*
• The audit committee of a Fortune 50 global company in conducting an internal investigation into allegations of impropriety involving complex accounting and financial practices*
• One of the world’s leading defense contractors in numerous internal investigations and on developing compliance best practices*
• A Fortune 100 global retailer in internal fraud, embezzlement, anti-corruption, and related matters in Asia and the Americas*
• Several publicly traded food, beverage, and alcohol companies in anti-corruption, fraud, and accounting practices investigations, as well as on continual improvement of internal compliance programs for these companies*
• Private equity-backed and privately held companies in matters involving allegations of fraud, corruption, and embezzlement* 
• A global commodities trading firm in investigating potential securities fraud and revenue-recognition issues involving complex swap and derivative agreements*
• A Fortune 500 engineering and construction firm in anti-corruption and fraud investigations in Latin America and proactive compliance matters*

Individual Executive Representations

• High-level corporate executives and affiliated individuals from around the world facing anti-corruption, fraud, money laundering, revenue-recognition, environmental, securities fraud, and other white collar investigations by the DOJ, SEC, US Commodity Futures Trading Commission (CFTC), and other agencies*
• A senior executive of a multinational advisory firm in obtaining time served related to a corruption scandal in South Africa*

Federal Prosecutorial Experience

• Conducted numerous global investigations into possible FCPA violations and related crimes by several major international companies and individuals, including:
  • Resolving a matter with a major global technology company for FCPA violations, resulting in a corporate guilty plea and over US$100 million in combined criminal and civil penalties and fines*
  • Securing a guilty plea by another global technology company’s senior executive for bribes paid to senior Panamanian government officials to obtain technology contracts*
• Prosecuted fraudulent “robo-signing” practices in the mortgage industry; the investigation was profiled on 60 Minutes and resulted in a guilty plea by a key executive to fraud-related charges, as well as a US$35 million fine with a publicly traded company related to the fraud*
• Prosecuted a former financial advisor for running a Ponzi scheme, which later turned into a murder-for-hire plot; following a federal jury trial, the defendant was sentenced to 30 years in prison and the case was made into an episode of American Greed*

*Matter handled prior to joining Latham

Thought Leadership

Publications

• Co-author, “M&A, Professional Perspective – DOJ Reveals Safe Harbor Policy for M&A Voluntary Self-Disclosures,” Bloomberg Law (October 9, 2023)
• Quoted, “Roger Ng to return to Malaysia,” Global Investigations Review (October 6, 2023)
• Co-author, “DOJ & SEC FCPA Enforcement Developments in 2022,” Bloomberg Law (January 2, 2023)
• Co-author, “Fine Over Bank Texts Signals Books, Records Crackdown,” Law360 (October 4, 2022)
• Quoted, “White Collar Clawbacks Pushed by DOJ Put Companies in Bind,” Bloomberg Law (September 29, 2022)
• Quoted, “WhatsApp, Signal Chats Targeted in DOJ Crackdown on Executives,” Bloomberg Law (September 27, 2022)
• Quoted, “New DOJ Monitorship Shows When Compliance Upgrades Aren’t Enough,” Bloomberg Law (April 21, 2022)
• Quoted, “U.S. Probes Examine Raytheon’s Dealings With Qatari Defense Contractor,” The Wall Street Journal “Risk & Compliance Journal” (September 7, 2021)
• Co-author, “Disclosure of Exculpatory Evidence in ‘Parallel’ Civil and Criminal Investigations,” The Anti-Corruption Report (April 28, 2021)
• Co-author, “Tax Deductions For FCPA Settlement Amounts,” FCPA Professor (March 30, 2021)
• Quoted, “TI’s 2020 CPI Lowers U.S. Ranking and Links Corruption to Healthcare Spend,” The Anti-Corruption Report (February 17, 2021)

Presentations

• Co-Chair, “21st Annual Anti-Corruption, Fraud & Global Compliance for Life Sciences Conference,” ACI (May 2026)
• Panelist, “Enforcement Hot Topics: The Impact of Recent Enforcement Actions on Your Compliance Program,” 11 Annual FoodBev Exchange (October 2023)
• Panelist, “Life Sciences and the Continuing Compliance Challenges of Ephemeral Messaging: DOJ’s Increasing Oversight and How to Resolve the Most Complex Dilemmas,” ACI’s FCPA & Anti-Corruption for the Life Sciences Industry Conference (May 2023)
• Panelist, “Corporate Compliance: Monaco Memo and Key Regulatory Developments,” Association of Corporate Counsel Chicago Seminar (February 2023)
• Panelist, “The New Realities of Corporate and Individual Liability Risks: Defense Counsel Perspectives on the DOJ’s Enforcement Posture and the Path Ahead,” ACI’s FCPA Conference (November 2022)
• Speaker, “Restitution Issues in High-Profile White-Collar Settlements,” American Bar Association’s 36th National Institute on White Collar Crime (October 28, 2021)
• Co-Chair, “GIR Connect: US,” Global Investigations Review (May 26, 2021)