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Jason Hungerford


Jason Hungerford


T:+44 20 7444 2474

Jason Hungerford is a US and UK-qualified investigations and compliance lawyer based in London. Previously based in Washington DC, Jason represents corporates and financial institutions in government and internal investigations, and he advises them on the design and testing of ethics and compliance programmes related to anti-bribery, economic sanctions, export controls, and anti-money laundering laws.  In the course of his practice, Jason represents clients in enforcement, licensing and interpretive matters before OFAC, HM Treasury OFSI, HM Revenue & Customs, the Export Control Joint Unit, the National Crime Agency, and the US State and Commerce Departments.

Jason is a frequent advisor to executives and boards of directors on the role of ethics, compliance and audit in corporate governance, including the systematic assessment of related processes, behaviours, 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 throughout Europe and the United States.  His experience covers a range of sectors, including aerospace and defence, manufacturing, engineering, financial institutions, energy, mining, FMCG and telecommunications.

A corporate lawyer by training, Jason also frequent advises 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, the UK Proceeds of Crime Act, and the UK Modern Slavery Act.  Jason is a member of the Money Laundering Task Force of the Law Society of England & Wales.

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  • Representative experience
    • 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.
    • Audit and testing of a global manufacturer's compliance programme, including transaction review and interviews in China, Singapore, Dubai, Europe and the United States.  Reporting data-driven results and recommendations to the board of directors.  Developing and executing remediation plans relating to financial control and compliance process improvements, training and employee discipline.
    • Investigation into alleged corrupt practices of a Middle East-based corporate, including reporting to the company's audit committee and developing remediation strategies including employee discipline, third-party agreements and potential civil claims.
    • 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.  Counsel on implementing the programme using existing communications, HR, legal and audit resources.
    • Investigation into alleged corrupt practices in the Brazilian operations of a European company. Conducted remediation measures, including dismissal of third parties and employees, as well as engagement with key customers.
    • 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 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.
    • Investigation into alleged corrupt dealings with Chinese state-owned entities by US and European entities of a multinational corporate.  Reporting to the board of directors and design of remediation programme and compliance improvements.
    • Development of an export control compliance programme for a major defence contractor under the terms of a government monitorship agreement.
    • Development of compensation methodologies for use by a major defence contractor in managing corruption risk as part of the company's third-party management programme.
    • Investigation into the alleged corrupt acquisition of operating licences in China, including separation negotiations with affected intermediaries and employees.
    • Investigation and voluntary self-disclosure by European defence company to UK authorities relating to suspected trade control violations.
    • Investigation and voluntary self-disclosure to UK Treasury relating to suspected dealings by a European branch with sanctioned individuals.
    • Financial crime due diligence and contractual negotiation for the disposal of overseas operations of a UK bank in several jurisdictions.
    • Anti-corruption due diligence and advice relating to the acquisition of sub-Saharan African assets by a Japanese trading house.
    • Investigation into alleged corrupt practices of the Austrian and Polish subsidiaries of a Europe-based global corporate, in response to dawn raids by those governments.
    • 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.
    • 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 a major defence and engineering company with respect to US and EU sanctions against Russia.
    • 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.
    • 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