Jonathan Zygielbaum is an attorney in the firm’s Washington, D.C. office and a member of the Anti-Corruption & Internal Investigations and White Collar & Regulatory Defense practice groups.
Jonathan represents companies in
government and internal investigations, congressional inquiries, and criminal
and civil enforcement proceedings, with a primary focus on matters involving allegations
of bribery and corruption under the U.S. FCPA, money laundering, sanctions
violations, and financial and accounting fraud. Jonathan has experience representing
telecommunications, aerospace, pharmaceutical, oil and gas, construction and
engineering, and financial services companies in matters involving the U.S.
Department of Justice, U.S. Securities and Exchange Commission, and Senate
Permanent Subcommittee on Investigations, among others.
Jonathan also represents
clients in Multilateral Development Bank enforcement proceedings, including
matters involving the World Bank, Asian Development Bank, African Development
Bank, Inter-American Development Bank and European Bank for Reconstruction and
Development. He has represented
companies and individuals during all phases of MDB sanctions proceedings,
including responding to initial allegations, negotiating settlement agreements,
litigating matters before first and second tier adjudicators, and aiding
clients in meeting compliance obligations imposed through sanctions or
settlement agreements.
In addition, Jonathan’s
practice involves assisting clients in designing, implementing, and testing corporate
compliance programs and providing regulatory guidance. He has helped clients establish cutting edge compliance
programs designed to mitigate corruption, fraud, money laundering, and
sanctions violations risks. Jonathan has
also acted on behalf of independent compliance monitors imposed by the U.S.
Department of Justice, U.S. Securities and Exchange Commission, U.K. Serious
Fraud Office, World Bank, African Development Bank and Asian Development Bank, and
has acted as intermediary counsel representing companies before independent
compliance monitors imposed by these same regulators.
Jonathan also works closely
with our corporate department to conduct anti-corruption focused due diligence
in connection with corporate transactions, including mergers, acquisitions and
de-SPACs.
Recognitions
2014 Capital Pro Bono High Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
2013 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
Highlighted Publications and Lectures
Executive Editor and Contributor for Hughes Hubbard & Reed’s annual FCPA & Anti-Bribery Alert
"The Art of Compliance: Addressing Anti-Money Laundering and Sanctions Risk Exposure in the Art Market," WorldECR, July 2020 (co-author with Ryan Fayhee and Tyler Grove)
"Trends in International Anti-Corruption Enforcement," BAU International University, Washington, DC, December 11, 2018
Court Admission
Court of Appeals of Maryland
Highlighted Matters
Internal and Government Investigations
Representation of multinational oil and gas company in connection with various anti-corruption and sanctions matters, including conducting internal investigations, anti-corruption compliance audits, and assisting with development and implementation of compliance program
Representation of multinational telecommunications company in connection with various anti-corruption matters, including DOJ and SEC inquiry, internal investigations, third party due diligence and development and implementation of compliance program
Representation of multinational oil field services company, including guidance regarding compliance with anti-corruption laws, and assistance with internal investigations, compliance reviews, and third-party due diligence
Conducted worldwide compliance systems review regarding use of third-party sales intermediaries for Fortune 500 pharmaceutical company
Conducted multi-year global compliance review of Innospec Inc. on behalf of the Corporate Compliance Monitor appointed by the U.S. Department of Justice, the U.S. Securities & Exchange Commission, and the U.K. Serious Fraud Office
Representation of auction houses in connection with sanctions and AML matters, including representing clients before the Senate Permanent Subcommittee on Investigations, conducting internal investigations, assisting with sanctions compliance, and designing and implementing compliance programs
Representation of Chinese state-owned global infrastructure contractor in connection with establishment and implementation of integrity compliance program
Representation of U.S. defense contractor in connection with internal investigations and various compliance initiatives
Representation of former partner of a private equity firm in connection with SEC investigation regarding potential violations of the Investment Advisors Act
Highlighted Matters
World Bank Group and Other Multilateral Development Banks
Representation of Chinese infrastructure contractor in connection with contested sanctions proceedings by The World Bank. Sanctions Board Decision No. 88 (Sanctions Case No. 372) issued June 29, 2016
Representation of Chinese engineering company in connection with investigation by Asian Development Bank related to alleged bidding fraud
Representation of multinational heavy machinery manufacturer in connection with Asian Development Bank investigation into alleged fraud
Conducted global compliance review of $100 billion construction company on behalf of compliance monitor appointed by World Bank
Conducted global compliance review of electrical equipment manufacturer on behalf of Independent Monitor appointed by African Development Bank
Representation of construction company in connection with negotiated resolution of a sanctions investigation by the African Development Bank, including assisting company in meeting obligations under its settlement and obtaining early release from debarment
Highlighted Matters
Selected Pro Bono Matters
Representation of multiple juvenile and adult foreign nationals in deportation proceedings