Jonathan Haray represents corporations and individuals in government investigations, securities and regulatory enforcement matters, and white-collar litigation. Recognized by Chambers USA and the National Law Journal as being a leading white-collar government investigations and criminal defense lawyer, Jonathan advises corporate clients on sensitive matters involving government regulators and law enforcement agencies, as well as in commercial disputes and internal investigations.
He has extensive government experience as a federal prosecutor, Securities Exchange Commission (SEC) litigator, and Navy Judge Advocate, including serving in leadership positions at the US Department of Justice (DOJ) and the nation’s largest US Attorney’s Office. Jonathan has supervised some of the Justice Department’s most complex and high-profile corporate and individual white-collar cases involving securities fraud, government procurement fraud, and regulatory and consumer offenses, and he has been entrusted to handle extremely challenging and high-profile matters.
Jonathan has conducted more than 50 criminal and civil trials, including three dozen jury trials.
Successfully defended the CEO of a government contractor IT company charged with conspiracy and bribery offenses, obtaining a complete post-indictment dismissal of all charges
Obtained a favorable SEC settlement for a leading telecommunications company following an investigation into alleged FCPA violations in Latin America
Defended a multinational telecommunications company in a DOJ Foreign Corrupt Practices Act of 1977 (FCPA) investigation resulting in a full declination of charges
Represented a Fortune Global 500 public company in a DOJ FCPA investigation involving multiple jurisdictions, obtaining a complete declination from prosecution
Conducted an internal investigation for a public US information technology company into alleged FCPA violations in Mexico and Latin America
Defended a major defense contractor in parallel civil and criminal investigations involving alleged violations of the False Claims Act
First-chaired a trial before the World Bank Sanctions Board for a European information technology company challenging charges of collusion and obstruction
Represented several senior executives in DOJ and SEC investigations into alleged accounting fraud and channel stuffing
Conducted an investigation into alleged spoofing on behalf of a derivatives trading firm and negotiated a favorable settlement with a national derivatives exchange
Represented an international bank in a sanctions-related joint investigation by the Office of Foreign Assets Control (OFAC), DOJ, and the District Attorney of New York
Defended a public US technology company in an SEC investigation concerning internal controls over financial reporting
Represented a public US information technology company in parallel DOJ and SEC investigations into alleged FCPA violations in India
Represented a senior executive of a national broker-dealer concerning Anti-Money Laundering (AML) compliance issues in an SEC investigation
Represented a large international trader of crude oil futures in an investigation into possible market manipulation
Defended a senior foreign exchange (FX) trader at a major bank in a multi-nation criminal investigation into alleged manipulation of FX rates
Education
J.D., Syracuse University College of Law cum laude
B.A., University at Albany
Awards
Chambers USA
Band 5, District of Columbia Litigation: White-Collar Crime & Government Investigations, (2021-2022)
Criminal Law Trailblazer, National Law Journal, (2020)
Distinguished Legal Writing, Burton Award, (2017)
"Standout Lawyer" of the District of Columbia FCPA Bar, Global Investigations Review, (2016)
Assistant Attorney General’s Award, Criminal Division, US Department of Justice
US Attorney’s Award for Exceptional Performance, US Department of Justice
Special Achievement Award for Superior Performance (six awards), US Department of Justice
Commendation, Federal Bureau of Investigation (FBI)
Commendation, IRS-Criminal Investigation
Commendation, Inspector General for the Department of Justice
Commendation, US Postal Inspection Service
Publications
Co-author, "Spoofing' Prosecutions: The DOJ's Approach," New York Law Journal, April 2, 2021
Co-author, "With Friends Like These: The Insider Trading Risk Presented By Family Members, Friends and Contractors," Securities Regulation Daily, July 16, 2019
Co-author, "Gov't Contractors, Be Prepared For FCA Parallel Proceedings," Law360, Apr 24, 2019
Co-author, "White Collar Crime Report," Bloomberg Law, Mar 31, 2017
Co-author, "Defending Against Insider Trading Claims," Practical Law, February/March 2016
Seminars
Moderator, "Conducting Parallel Criminal and Civil False Claims Act Investigations", Federal Bar Association Qui Tam Conference, February 28, 2019
Panelist, "Using Experts in Qui Tam Cases, Federal Bar Association Qui Tam Conference", February 27, 2018
Panelist, "Ethical Issues in Large Corporate Investigations, Association of Corporate Counsel", New Jersey, September 16, 2016
Panelist, "Government Negotiations, Foreign Corruption 2016 - 9th Annual Chicago White Collar Crime and Corporate Governance Seminar", April 13, 2016
Moderator, "Trends in Financial Crimes and High Tech Fraud, American Bar Association", Tort Trial & Insurance Practice Section, November 6, 2015
Prior Experience
Jonathan has served in several senior positions within the US Department of Justice, including most recently as a Principal Assistant Deputy Chief of the Criminal Division’s Fraud Section, where he supervised complex corporate and individual prosecutions in the Market Integrity and Major Frauds Unit, led efforts to expand the use of data to identify and prosecute market abuses, and coordinated with regulators and enforcement agencies in the US and abroad. Jonathan also served as an Assistant Special Counsel at the Justice Department from 2022-2023.
Earlier in this career, he served as Deputy Chief of the Fraud and Public Corruption Section at the US Attorney's Office in Washington, DC, where he supervised senior prosecutors and oversaw white collar investigations and litigation. During more than a decade as an Assistant US Attorney, Jonathan prosecuted cases involving FCPA violations, False Claims Act violations, healthcare fraud, corporate and insurance fraud, money laundering, and Bank Secrecy Act violations. He also prosecuted high profile public corruption cases and led the successful prosecution of the first sitting Washington, DC Council member ever to be charged with felony corruption offenses, resulting in what the Washington Post described as “the most severe criminal sanction ever given to a local elected official in the District.” He also served as a senior federal prosecutor investigating and litigating homicide and other violent crime cases and argued cases before the District of Columbia Court of Appeals.
Jonathan also served as an Assistant Chief Litigation Counsel for the Securities and Exchange Commission, where he handled complex securities enforcement matters, including cases involving FCPA and securities fraud violations, and earlier he served in the US Navy, Judge Advocate General’s Corps.
Teaching & Professional Activities
Adjunct Law Professor, Trial Practice, George Washington University Law School
Memberships And Affiliations
President, Assistant United States Attorney Association of the District of Columbia (2019 — 2021)
Board Member, Assistant United States Attorney Association of the District of Columbia
Barrister, Edward Bennet Williams Inn of Court
Board of Directors, Washington Lawyers’ Committee for Civil Rights and Urban Affairs
