USA
Practice Areas
WHITE COLLAR DEFENSE, INVESTIGATIONS & COMPLIANCE
LITIGATION & DISPUTE RESOLUTION
LIFE SCIENCES
Work Highlights
First Brands Group: Official Committee of Unsecured Creditors in Chapter 11 case of First Brands Group, an automotive parts manufacturer.
Some of Steve’s notable matters handled prior to joining Brown Rudnick include:
Represented Vantage Drilling in connection with a DOJ and SEC investigation into alleged violations of the FCPA arising from the company’s dealings with Petrobras.
Represented and conducted numerous internal investigations for Sanofi in a joint DOJ and SEC investigation of alleged FCPA violations in various countries in emerging markets.
Represented a former employee of a major financial institution in connection with a DOJ criminal investigation into alleged manipulation of LIBOR.
Represented HMT LLC in connection with a DOJ investigation into potential violations of the FCPA in Asia and South America, which resulted in a declination of prosecution under the DOJ’s recently announced FCPA Pilot Program.
Represented and obtained DOJ and SEC declination for Innodata Inc. in connection with its disclosure to the DOJ and SEC of potential improper payments by employees of one of its foreign subsidiaries in Asia.
Represented an India-based manufacturer of mining equipment in a joint DOJ and SEC investigation of alleged FCPA violations.
Represented two senior executives of a global operator of retail department stores in a joint DOJ and SEC investigation of alleged FCPA violations in Central America and Asia.
Represented two former employees of a multinational spirits company in a joint DOJ and SEC investigation of alleged FCPA violations in Russia.
Represented three former executives of a global pharmaceutical company in a joint DOJ and SEC investigation of alleged FCPA violations in several countries including Russia and Venezuela.
Represented two senior executives of a global oil services industry company in a DOJ investigation of alleged violations of U.S. export controls and sanctions laws.
Conducted an internal investigation for a financial services company regarding allegations of improper payments in connection with its Nigerian operations.
Represented a U.K.-based, global specialty chemicals company in a DOJ investigation of alleged violations of U.S. export controls and sanctions laws.
Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a U.K.-based, global specialty chemicals company.
Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a multinational telecommunications company.
Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a multinational financial services company.
Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a global tax-free shopping and related financial services company.
Designed anti-bribery and corruption policies and procedures for a multinational family dining and entertainment company.
Lead outside counsel for FCPA due diligence on Intel’s acquisition of Altera Corp.
Lead outside counsel for FCPA due diligence on Norwegian Cruise Line Holdings’ acquisition of Prestige Cruises International.
Lead outside counsel for FCPA due diligence on General Electric Co’s. acquisition of Lufkin Industries.
Lead outside counsel for FCPA due diligence on Oracle Corp.’s acquisition of Acme Packet.
Designed anti-bribery and corruption policies and procedures for a multinational telecommunications equipment manufacturer.
Lead outside counsel for FCPA due diligence on publicly traded, multinational health care company’s acquisition of the Eastern European operations of a competitor.
Provided FCPA training for the Board of Directors of a global clothing manufacturer and retailer.
Advising a global commercial aircraft leasing company on various anti-bribery and corruption compliance matters.
Obtained dismissal of federal civil RICO action and related state claims brought by Greenpeace against The Dow Chemical Company.
Career
Steven Tyrrell is a partner in the Firm’s White Collar Defense, Investigations & Compliance Practice Group. His practice focuses on white collar criminal defense, regulatory enforcement matters, and internal investigations, with an emphasis on matters involving the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, securities fraud, accounting fraud and health care fraud, among other areas. He also advises clients on FCPA and anti-corruption due diligence in the context of M&A transactions and assists clients in developing and executing anti-corruption internal compliance programs.
Steve previously served as chief of the U.S. Department of Justice’s Fraud Section from 2006 through 2009 and led the investigation, prosecution and coordination of a broad range of sophisticated economic crime matters and enforcement initiatives. He also played a key role advising DOJ leadership on white collar crime-related legislation, crime prevention, public education and the DOJ’s Financial Fraud Enforcement Task Force.
Prior to that role, Steve served as deputy chief of the DOJ’s Counterterrorism Section of the Criminal Division, where he supervised a team of attorneys in connection with the investigation, prosecution and coordination of a variety of international terrorism and terrorist financing matters. He also led a number of high-profile national security investigations, and trained federal prosecutors and agents on relevant national security statutes, policies and practices.
In addition, Steve served as an assistant U.S. attorney in the U.S. Attorney’s Offices in the Southern District of Florida and the Northern District of New York for more than 15 years. During that time, Steve investigated and prosecuted a variety of criminal cases, with an emphasis on white collar matters, including but not limited to securities fraud, health care fraud, government contract fraud, bank fraud, tax fraud, FDA fraud and public corruption, as well as related money laundering and asset forfeiture work. He also was lead counsel for the United States in nearly 40 criminal jury trials.
Steve has been recognized by multiple publications. In 2021, Steve was named among the Top 30 FCPA Practitioners in the United States by Global Investigations Review, which called him a “a sophisticated and nuanced lawyer who knows the ins and outs of the FCPA” and noted that he “has a declination record that few lawyers can match.” Steve is currently recognized in Chambers Global and Chambers USA as one of the leading lawyers nationally and in Washington, D.C., for white collar crime, government investigations, and FCPA. Chambers notes that he “offers impressive experience handling big-ticket investigations” and “knows what he is doing and how to deliver,” and has quoted sources calling him “incredibly smart and strategic,” “fantastic,” “calm and levelheaded,” with “a ton of experience and insight” and “impeccable integrity.” In 2015, The National Law Journal recognized Steve as one of its inaugural “Trailblazers” nationwide for his distinguished career in the white collar crime area, and in 2020 the same publication honored him as one of its “Trailblazers” in Washington, D.C., noting that he has long been “at the forefront of … the investigation, prosecution, and defense of allegations of corporate crime.” Since 2013, Steve also has been recognized as a recommended lawyer for Corporate Investigations and White-Collar Criminal Defense by Legal 500 US, in which clients have praised him as, among other things, “patient and collaborative.” He is a recognized authority and frequent speaker on a host of white collar topics, including FCPA enforcement, securities fraud, corporate charging decisions, use of deferred and non-prosecution agreements, and monitors.
Prior to joining Brown Rudnick, Steve was a partner and co-head of Weil, Gotshal & Manges’ global White Collar Defense, Regulatory and Investigations practice. He also served as managing partner of Weil’s Washington, D.C., office for almost 10 years.
Early in his career, Steve served as a law clerk to Honorable Thomas J. McAvoy, U.S. District Court Judge for the Northern District of New York.
Steve received his J.D. from New York Law School (cum laude) where he was also the research editor of the Law Review.
Professional Memberships
Real Estate Bar Association (REBA)
Boston Bar Association
Massachusetts Bar Association (appointed to Property Law Section Council, 1995-1998)
American Bar Association: Real Property, Trust and Probate Law, and Business Law Sections
International Council of Shopping Centers (ICSC): Law Conference Planning Committee (2023-present); Trustees’ Distinguished Service Award (2022); Legal Advisory Council member (2012-present) and Chair (2019-2022); New Retail Study Lease Model Task Force (2020-2021); Ambassador (2014-present); State Director (2009-2012); New England Idea Exchange Chair (2009) and Co-Chair (2008); and Next Generation Advisory Group (2005-2010), Eastern Division Chair (2007-2009) and State Chair (2005-2007)
National Retail Tenants Association (NRTA)
NAIOP
Urban Land Institute
Real Estate Finance Association (REFA)
