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Jason Hungerford


Jason Hungerford


T:+44 20 7444 2474

Jason Hungerford is a corporate compliance and investigations lawyer based in London. Jason Hungerford advises corporates on the ethics and compliance programmes and investigations related to anti-bribery, economic sanctions, export controls, and anti-money laundering laws.

Previously based in Washington DC, Jason is an advisor to multinational companies on the design and implementation of ethics compliance programmes and the conduct of internal and regulator-led investigations.  Increasingly, his focus is on testing and assurance of compliance processes and the systematic assessment of managerial culture and ethical messaging uptake.  Jason’s investigations, risk assessment and testing work has covered a range of jurisdictions, with most extensive work in China and southeast Asia, Brazil, Russia, the Nordic region and through Europe and the United States.  His experience covers a range of sectors, including manufacturing, financial institutions, energy, mining, telecommunications, and aerospace and defence.

Jason is also a frequent advisor to corporates and financial institutions with respect to the financial crime-regulatory aspects of M&A, joint venture, private equity, capital markets and debt transactions, including due diligence, negotiation and post-acquisition integration.

Jason advises primarily on US and EU economic sanctions, the US Foreign Corrupt Practice Act, the UK Bribery Act, US and EU dual-use and military end-use trade controls, and the UK Proceeds of Crime Act.

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  • Representative experience
    • Design and implementation of anti-corruption programme for a manufacturer operating in 130 countries through five distinct business divisions. Design of comprehensive work plan for the implementation of the programme, from the hiring of a head of compliance to regular audits of the programme. Drafting of group-level and local policies and procedures regarding a variety of issues, including third-party due diligence and gifts and entertainment, and I counselled the client on implementing the programme using existing communications, HR, legal and audit resources.
    • Design and implementation of an economic sanctions compliance programme for a European oil and gas company’s global operations. Workstreams included risk assessment exercises, drafting of policies, executive training programmes, evaluation of regulatory and reputational exposure and design of project-based and operational due diligence procedures.
    • Investigation into alleged corrupt practices in the Brazilian operations of a European company. Led project team, including more than four weeks of interviews. Conducted remediation measures, including dismissal of third parties and employees, as well as engagement with key customers.
    • Investigation into alleged corrupt practices of the Austrian and Polish subsidiaries of a client, in response to dawn raids by those governments.
    • Investigation into Scandinavian telecommunications operator with respect to implications under local anti-corruption law, as well as exposure to FCPA jurisdiction. Investigations covered multiple Eurasian jurisdictions. Remedial efforts involve liaison with US counsel.
    • Development of an export control compliance programme for a major defence contractor under the terms of a government monitorship agreement.
    • Advising a major defence and engineering company with respect to US sanctions against Russia.
    • Advising a Scandinavian defence and engineering company in relation to export control aspects of a proposed acquisition.
    • Advising on US and EU sanctions implications for the acquisition of an EU integrated operator in the oil and gas sector. Preparation of advice for the purpose of negotiations with relevant regulators.
    • Investigation for a major international bank, in response to inquiries by the Securities and Exchange Commission. Managing project team and investigation methodology, including potential FCA implications; liaising with US counsel and third-party service providers.
    • Design and implementation of global third-party review systems for financial institutions and manufacturers, designed to review all existing service provider relationships and to leave in place a forward-looking due diligence procedure and associated financial controls.
    • Design of board-level action plans for addressing inadequate procedures within a company, including implementation of an anti-bribery compliance programme, third-party review, review of financial controls, review of internal audit function, creation of internal investigative function and internal/external communications.
    • Conducting risk assessment and investigations fieldwork in the European Union, China, Russia, Ukraine, Brazil and the United States.
    • Due diligence and regulatory risk mitigation with respect to variety of M&A, ECM and DCM transactions in a broad range of sectors. Design and execution of pre-acquisition, pre-disposal and pre-listing review exercised, as well as post-completion integration and remediation programmes.
    • Advising several Chinese companies with respect to EU and US sanctions in connection with a IPOs on the Hong Kong Stock Exchange;
  • Admissions
    • Attorney at Law, admitted in New York
    • Attorney at Law, admitted in Washington DC
    • Solicitor, qualified in England & Wales