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. He represents clients in multi-jurisdictional enforcement matters and internal investigations involving anti-corruption, fraud, anti-money laundering (AML), and sanctions issues. Jonathan has significant experience conducting compliance reviews and risk assessments, and designing and implementing compliance programs for companies in an array of industries and jurisdictions. He also represents clients in connection with Multilateral Development Bank enforcement actions, including matters involving the World Bank, African Development Bank, and Asian Development Bank.
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
Co-author, with Ryan Fayhee and Tyler Grove, "The Art of Compliance: Addressing Anti-Money Laundering and Sanctions Risk Exposure in the Art Market," WorldECR, July 2020
"Trends in International Anti-Corruption Enforcement," BAU International University, Washington, DC, December 11, 2018
Court Admission
Court of Appeals of Maryland
Highlighted Matters
Anti-Corruption, AML, and Sanctions
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 oil field services company, including provision of 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 conducting internal investigations, responding to government 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 Chinese state-owned 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 foreign nationals in deportation proceedings