
Jonathan Haray
PartnerJonathan 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 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.
Jonathan brings extensive government experience as a federal prosecutor, Securities and Exchange Commission (SEC) litigator, and Navy Judge Advocate, including leadership positions at the US Department of Justice's (DOJ) Fraud Section and the nation's largest US Attorney's Office. At DOJ, he supervised some of the Department's most complex and high-profile white-collar cases against corporations and individuals, involving securities fraud, government procurement fraud, and regulatory and consumer offenses. Clients regularly entrust him with their most challenging and important matters.
Jonathan is also a tested first-chair trial attorney, having conducted more than 50 criminal and civil trials, including three dozen jury trials.
EXPERIENCE
False Claims Act Matters
- Defended a major defense contractor in parallel civil and criminal investigations involving alleged violations of the False Claims Act
- Represented a Fortune 100 medical device manufacturer in response to a DOJ civil investigative demand into potential Anti-Kickback Statute and False Claims Act allegations
- Represented affiliated international businesses in response to qui tam lawsuit, DOJ investigation, and related settlement resolving alleged False Claims Act violations arising loans obtained through the Paycheck Protection Program
- Represented a Fortune 100 aerospace and defense company in an investigation and voluntary self-disclosure related to alleged False Claims Act violations based on manufacturing quality issues
Securities and Financial Fraud Matters
- Represented a government contractor in connection with parallel SEC and DOJ investigations into possible insider trading
- Represented a private investment firm in connection with parallel SEC and DOJ investigations into securities and wire fraud
- 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 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
Foreign Bribery and Corruption Matters
- Obtained a favorable SEC settlement for a leading telecommunications company following an investigation into alleged violations of the Foreign Corrupt Practices Act (FCPA) in Latin America
- Represented a Fortune 100 multinational pharmaceutical company in response to an SEC investigation into alleged FPCA violations in Mexico, resulting in no enforcement action
- Defended a multinational telecommunications company in a DOJ 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
- Represented a public US information technology company in parallel DOJ and SEC investigations into alleged FCPA violations in India
Civil and Criminal Litigation Matters
- Successfully defended the chief executive officer (CEO) of a government contractor information technology (IT) company charged with conspiracy and bribery offenses, obtaining a complete post-indictment dismissal of all charges
- First-chaired a trial before the World Bank Sanctions Board for a European information technology company challenging charges of collusion and obstruction
- Represent a major health insurer in a lawsuit involving allegations of malicious prosecution
- Defended a large heath center against a former executive’s lawsuit claiming improper retaliation and wrongful termination
- Represented a leading defense contractor against employee claims of improper retaliation
Awards and Recognitions
Chambers USA
- Band 6, District of Columbia Litigation: White-Collar Crime & Government Investigations, (2026)
- Band 5, District of Columbia Litigation: White-Collar Crime & Government Investigations, (2021 – 2022)
National Law Journal
- Criminal Law Trailblazer, (2020)
Additional Recognitions
- The Legal 500 United States, Recommended, White-Collar Criminal Defense, (2015)
- 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
- J.D., Syracuse University College of Law
cum laude - B.A., University at Albany
Bylines
- "US Department of Justice secures conviction in long-anticipated Foreign Corrupt Practices Act trial of ex-coal executive," Energy Law Report, July 6, 2026
- Co-author, "White House Announces National Fraud Enforcement Division: Top Points," Journal of Federal Agency Action, May – June 2026
- Co-author, "Historical Patterns Cannot Justify Contemporary Violations of Constitutional Guarantees—Renewed Constitutional Attacks on FCA Qui Tam Provisions," The Legal Intelligencer, September 10, 2025
- Co-author, "Securities and Exchange Commission Roundtable Presents Both Risks and Opportunities of Artificial Intelligence in the Financial Industry," The Banking Law Journal, July – August 2025
- 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 DOJ, 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 to 2023.
Earlier in his 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 District of Columbia 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 SEC, 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 Experience
- Professorial Lecturer in Law, Trial Advocacy, 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