Steven A. Tyrrell

Steve previously served as Chief of the U.S. Department of Justice’s Fraud Section from 2006 through 2009. In that capacity, he led the investigation, prosecution, and coordination of a broad range of sophisticated economic crime matters and enforcement initiatives, including matters involving the Foreign Corrupt Practices Act, corporate, securities, commodities and investment fraud, health care fraud, procurement fraud, stimulus and rescue fraud, mortgage fraud, consumer fraud, and identity theft. He also played a key role advising Department leadership on white collar crime-related legislation, crime prevention, public education and the Department’s Financial Fraud Enforcement Task Force.

Prior to Steve’s appointment as Chief of the Fraud Section in 2006, he served as Deputy Chief of the 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. Steve also led a number of high-profile national security investigations and trained federal prosecutors and agents on relevant national security statutes, policies and practices.

Steve also served as an Assistant US Attorney in the US Attorney’s Offices in the Southern District of Florida and the Northern District of New York. During his more than fifteen years as an Assistant US Attorney, 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 forty criminal jury trials.

In 2021, Steve was recognized 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 expertise. Chambers notes that he “offers impressive experience handling big-ticket investigations” 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 expert 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.

Early in his career, Steve served as Law Clerk to the Honorable Thomas J. McAvoy, United States District Court Judge for the Northern District of New York.

Steve is a graduate of New York Law School where he was the Research Editor of the Law Review.

Key Representations

• Representing Vantage Drilling in connection with a DOJ and SEC investigation into alleged violations of the FCPA arising from the company’s dealings with Petrobras.
• Representing and conducting an internal investigation for Sanofi in a joint DOJ and SEC investigation of alleged FCPA violations in various countries in emerging markets.
• Representing 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 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.
• Representing a senior executive of a global operator of retail department stores in a joint DOJ and SEC investigation of alleged FCPA violations in Central America and Asia.
• Representing two former employees of a multi-national spirits company in a joint DOJ and SEC investigation of alleged FCPA violations in Russia.
• Representing two senior executives of a global oil services industry company in a DOJ investigation of alleged violations of US 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 UK-based, global specialty chemicals company in a DOJ investigation of alleged violations of US export controls and sanctions laws.
• Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a UK-based, global specialty chemicals company.
• Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a multi-national telecommunications company.
• Designed and assisted in the implementation of anti-bribery and corruption policies and procedures for a multi-national 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 multi-national 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 Corporation’s acquisition of Acme Packet.
• Designed anti-bribery and corruption policies and procedures for a multi-national telecommunications equipment manufacturer.
• Lead outside counsel for FCPA due diligence on publicly traded, multi-national 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.