Jonathan Zygielbaum

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.

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

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

Selected Pro Bono Matters

• Representation of multiple juvenile and adult foreign nationals in deportation proceedings