Practice focuses on international trade, involving regulatory and enforcement actions by the U.S. Department of Justice (DOJ), as well as regulators at the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC).
Served as a prosecutor for the DOJ’s National Security Division, Counterintelligence and Export Control Section.
Previous member of the DOJ Foreign Investment Review Staff on the Committee on Foreign Investment in the United States (CFIUS).

Jonathan is a partner in Akin’s international trade practice. He is a former federal prosecutor with the DOJ, where he handled prosecutions relating to violations of U.S. espionage, economic sanctions, money laundering and export control laws.

Jonathan has also represented companies in anti-corruption matters before the DOJ, Securities and Exchange Commission and before various multilateral development banks. He has also regularly handled matters before the Foreign Agents Registration Act (FARA) Unit of the DOJ.

He has served as an independent monitor of companies, including those that have entered into the World Bank disclosure program or are the subject of audits by multinational development banks relating to allegations of corruption, collusion and undisclosed agents and on the Special Compliance Officer team reporting to DDTC regarding compliance with a Consent Agreement relating to export control laws.

In addition, Jonathan was retained by the National Aeronautics and Space Administration (NASA) as part of an investigation into the Space Shuttle Columbia accident and compensation to the families of the crew.

Jonathan represents clients nationally and internationally in a variety of matters, including:

White collar criminal cases
Administrative enforcement matters
Trade-related due diligence
Integration issues in mergers and acquisitions
Internal investigations
Audits
Temporary denial orders (TDOs) and Entity Listings
Industry outreach visits
Entity list designations
Voluntary self-disclosures
Independent Monitorships
Corporate compliance issues.

Jonathan’s practice also covers anti-money laundering, economic sanctions, export control and fraud investigations involving international trade and trade finance, including investigations relating to potential violations of U.S. anti-money laundering statutes; tax laws and regulations; the International Emergency Economic Powers Act; the Export Control Reform Act, the Trading with the Enemy Act; the FARA, and the Arms Export Control Act.

During his time with the DOJ, Jonathan handled a number of cases, including a matter that resulted in the first arrests and prosecution of employees of a European freight-forwarding company for violations of U.S. export control laws, the first arrest and prosecution of an illicit procurement network obtaining improvised explosive device parts from the United States and some of the largest anti-money laundering and sanctions cases in U.S. history, receiving multiple commendations and awards for excellence in the process from various agencies, including DOJ and BIS.

Jonathan also works with the licensing agencies and civil enforcement authorities on numerous international trade and trade finance matters, including providing clients with advice on licensing, regulation interpretation and voluntary self-disclosures. He worked extensively in training U.S. and non-U.S. law enforcement agencies on export control enforcement efforts. Jonathan previously served on the DOJ’s Foreign Investment Review staff, which serves on the CFIUS review process.

Representative Work

Export Controls and Economic Sanctions

Defended and favorably resolved a multi-agency enforcement action against a semiconductor design company involving the DOJ, BIS, and FBI for alleged export control violations; also successfully defended against a related suspension and debarment proceeding initiated by the Department of Defense.
Represented a tire manufacturer in a DOJ investigation concerning allegations of tariff evasion tied to imports.
Defended and resolved a sanctions enforcement matter involving a major consulting firm arising from its voluntary self-disclosure to OFAC.
Successfully obtained the delisting of a former foreign head of state designated by OFAC and the Department of State as a Specially Designated National based on alleged corruption and terrorism-related conduct.
Defended a large semiconductor manufacturing company in an investigation by BIS into alleged export control violations.
Defended and resolved a sanctions enforcement matter involving a major international bulk shipping company before OFAC and secured a declination from DOJ.
Defended and resolved a multi-agency criminal and civil export control matter involving a 3D printing company, addressing alleged EAR and ITAR violations related to exports of technical data to China; secured a DOJ declination of criminal charges.
Represented a Chinese telecommunications company in connection with two monitorships and in responding to enforcement actions by DOJ and BIS.
Defended a global technology company in a multi-agency sanctions and export control investigation involving DOJ, Commerce, State, Homeland Security, Treasury, and Defense.
Defended a global manufacturing company in a sanctions and export control investigation conducted by the FBI and BIS.
Defended a publicly traded semiconductor company in an administrative investigation by BIS concerning alleged export control violations, including due diligence and classification issues related to integrated circuits.
Represented a leading semiconductor equipment company in connection with U.S. law enforcement outreach to its foreign offices.

Represented a major consulting company in a voluntary self-disclosure and regulatory enforcement action by the U.S. Treasury Department’s Office of Foreign Assets Control into alleged economic sanctions violations.
Defended a publicly traded company in the semiconductor industry regarding an administrative investigation by the Department of Commerce’s Bureau of Industry & Security into alleged export control violations regarding due diligence and classification issues associated with certain integrated circuits.
Successfully resolved and settled numerous OFAC, BIS and DDTC cases involving apparent violations.
Represented a company as part of an industry outreach by U.S. law enforcement to its offices.

Anticorruption/Anti-Money Laundering

Represented several employees in a large European financial institution involving alleged violations of U.S. economic sanctions and joint investigations by the U.S. Attorney’s Office for the Southern District of New York, New York County District Attorney’s Office, OFAC, N.Y. Department of Financial Services and the Federal Reserve.
Defended an anti-money laundering officer with a large European financial institution involving alleged violations of U.S. economic sanctions and anti-money laundering statutes.

Multinational Development Banks

Representing a non-U.S. energy and infrastructure company in connection with a World Bank investigation relating to a contract for a project in an African nation.
Engaged as the independent monitor on behalf of the World Bank for a company that participated in the Voluntary Disclosure Program.

CFIUS

Advised a large specialty insurance company on the placement of insurance policies to cover CFIUS risk associated with a proposed acquisition.
Conducted CFIUS-related due diligence on a proposed U.S. target for acquisition by a foreign private equity fund.

Other White Collar Matters

Settled alleged tax violations by a private Swiss financial institution that identified as a Category 2 Bank under the DOJ Program for Swiss Banks and participated in the DOJ’s voluntary disclosure program.

Represented a major consulting company in a voluntary self-disclosure and regulatory enforcement action by the U.S. Treasury Department’s Office of Foreign Assets Control into alleged economic sanctions violations.
Defended a publicly traded company in the semiconductor industry regarding an administrative investigation by the Department of Commerce’s Bureau of Industry & Security into alleged export control violations regarding due diligence and classification issues associated with certain integrated circuits.
Successfully resolved and settled numerous OFAC, BIS and DDTC cases involving apparent violations.
Represented a company as part of an industry outreach by U.S. law enforcement to its offices.

Anticorruption/Anti-Money Laundering

Represented several employees in a large European financial institution involving alleged violations of U.S. economic sanctions and joint investigations by the U.S. Attorney’s Office for the Southern District of New York, New York County District Attorney’s Office, OFAC, N.Y. Department of Financial Services and the Federal Reserve.
Defended an anti-money laundering officer with a large European financial institution involving alleged violations of U.S. economic sanctions and anti-money laundering statutes.

Multinational Development Banks

Representing a non-U.S. energy and infrastructure company in connection with a World Bank investigation relating to a contract for a project in an African nation.
Engaged as the independent monitor on behalf of the World Bank for a company that participated in the Voluntary Disclosure Program.

CFIUS

Advised a large specialty insurance company on the placement of insurance policies to cover CFIUS risk associated with a proposed acquisition.
Conducted CFIUS-related due diligence on a proposed U.S. target for acquisition by a foreign private equity fund.

Other White Collar Matters

Settled alleged tax violations by a private Swiss financial institution that identified as a Category 2 Bank under the DOJ Program for Swiss Banks and participated in the DOJ’s voluntary disclosure program.

"He combines outstanding subject matter knowledge with the ability to convey practical advice and risk in a way we can process it and use it to make our own decisions."

Chambers Global, 2022

Education
J.D., Georgetown University Law Center, 2002
B.A., Villanova University, summa cum laude, 1999

Bar Admissions
District of Columbia
Maryland

Recognitions

Chambers Global, International Trade: Export Controls & Economic Sanctions, 2024-2025.
Chambers USA, International Trade: Export Controls & Economic Sanctions, 2021-2025.
The Legal 500 US, International Trade, 2021-2024.
U.S. Department of Commerce, Office of Export Enforcement, Award for Excellence, 2010.
U.S. Department of Justice, Assistant Attorney General for the National Security Division, Special Commendation Award, 2009.
U.S. Department of Justice, National Security Division, Award for Excellence, 2008-2010.

Speeches and Publications

“International Trade & Tariffs: Understanding the Landscape,” Q Street and GATT DC, March 6, 2025.
“As the World (Bank) Turns: Compliance and Enforcement Principles in World Contracting,” Akin Seminar, New York, October 1, 2015 and Houston and Dallas, February 10 and 11, 2016.
“It’s Bound to Happen (and Probably Already Has): Handling Violations,” Interactive Export Controls Workshop Export Compliance Training Institute, Alexandria, September 15 and 16, 2015.
Speaker, EAR Export Controls Seminar, Export Compliance Training Institute, San Francisco, June 15 and 16, 2015.
“Sanctions Compliance Challenges Facing Financial Institutions,” ABA Section of International Law Export Controls and Economic Sanctions Committee, New York, May 19, 2015.
“Policy, Politics and Proliferation: Planning for the P5+1 Joint Comprehensive Plan of Action Regarding Iran,” Webinar, April 21, 2015.
Panelist, “Critical Global Business Issues: When Theory Meets Practice,” Santa Clara University School of Law’s 2015 International Law Symposium, Santa Clara, February 2015.
Co-author, Ryan Fayhee and Tyler Grove, "7 Enforcement Predictions For US Export Controls, Sanctions," Law360, December 2023.