Jason Hungerford is a US and UK-qualified investigations and regulatory partner in the government global trade group of the London office.
Previously based in Washington DC, Jason advises corporates and financial institutions on economic sanctions and export controls, anti-corruption and anti-money laundering in the context of investigations, complex transactions and compliance programme development and testing.
Jason advises corporates across a range of sectors, in particular aerospace and defence, oil and gas, mining, shipping, transportation, engineering and heavy machinery, and FMCG. He also works closely with a range of financial institutions, insurers and brokers. Jason's investigations and compliance work has included mandates in China, Southeast Asia, Russia, Brazil, the United States, the Middle East, the Nordic region and throughout Europe.
Jason is an advisor to executives and boards of directors on the role of ethics, compliance and audit in corporate governance, including the systematic assessment of related procedures and controls, process management, behaviours, managerial culture and messaging uptake.
Jason also frequently 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 focuses on US and EU economic sanctions; US, UK and EU dual-use and military end-use trade controls; the Foreign Corrupt Practices Act and the UK Bribery Act; the UK Proceeds of Crime Act, and the UK Modern Slavery Act. In the course of his practice, Jason represents clients in related enforcement, licensing and interpretive matters before OFAC, HM Treasury OFSI, HM Revenue & Customs, the UK Export Control Joint Unit, the US State Department and the US Commerce Department.
Jason serves on the Law Society of England & Wales's Money Laundering Task Force as a financial sanctions advisor.
Representative experience (handled prior to joining Mayer Brown)
- 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.
- 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
- Corruption-related investigation for a major international bank in response to inquiries by the US Securities and Exchange Commission with respect to operations in Venezuela.
- Conducting an investigation on behalf of a major European aerospace and defence company into the company’s sales practices in the United Kingdom. Representation of the company in a voluntary self-disclosure to HM Revenue & Customs and liaison with the Export Control Join Unit.
- 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.
- 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.
- Investigation into the alleged corrupt acquisition of operating licences in China, including separation negotiations with affected intermediaries and employees.
- 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 an economic sanctions compliance programme for a European oil and gas company's global operations. Work streams 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.
- Advising a major aerospace and defence contractor on the design and implementation of its export control compliance measures, whilst it was under a consent agreement by the US State Department over historic violation of the US International Traffic in Arms Regulations.
- 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.
- 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.
- 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.
- Design and implementation of a global third-party due diligence system for a major European financial institution and manufacturers, to mitigate risk of payments to business introducers.
- 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 an audit of the performance of an oil and gas major's anti-corruption compliance programme in Russia.
- Conducting due diligence and drafting contractual provisions on behalf of a major European bank on the sanctions and anti-corruption aspects of a number of its divestments in Europe and Africa. As part of our work, we supported the client’s applications to HM Treasury OFSI for guidance and authorisation and liaised with our Paris office for parallel licensing from the French treasury.
- Advising a European supermajor on the US and EU sanctions implications of its joint ventures with Rosneft.
- Leading negotiations for a maritime transportation company on sanctions in respect of the charter of its vessels to a Russian gas project, including engagement with OFAC on a number of occasions to obtain guidance on the client’s behalf.
- Advising a major European bank on EU and US sanctions in relation to the financing of a pipeline project, including engagement with the US State Department Office of Economic Policy and Implementation and the Bureau of Energy Resources on matters of first impression.
- Anti-corruption due diligence and advice relating to the acquisition of sub-Saharan African assets by a Japanese trading house.
- Anti-corruption due diligence and negotiation of terms for joint venture between two major rail equipment manufacturers.
- 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.
- New York
- England and Wales
- Listed under 'Other key lawyers' - Legal 500 2020.