Jonathan Chibafa

Jonathan leads internal investigations and advises on financial crime, fraud, sanctions, and asset freezing orders, representing companies globally in criminal, compliance, and governance matters, including high-risk jurisdictions and emerging markets projects.

• Led an internal investigation into allegations of bribery of foreign officials across several high-risk jurisdictions.
• Advised companies and company directors facing the threat of criminal prosecution from Companies House for late filings.
• Instructed by an Emerging Markets development finance fund to conduct two internal investigations following allegations of financial wrongdoing in relation to public infrastructure projects.

Jonathan advises global companies on ESG compliance, supply-chain risks, modern slavery, and reputational issues, designing due diligence procedures, conducting risk assessments, and implementing mitigation strategies across high-risk jurisdictions and complex international operations.

• Conducted a global ESG supply chain review for a US-listed retail company with a large global footprint.
• Instructed by a global pharma group to review and analyse the company’s UK third-party supplier oversight and bribery and corruption compliance programmes.
• Led forced labour supply chain audits for companies across several jurisdictions.

Jonathan is a recognised anti-bribery expert, advising global companies on corruption risks, compliance programmes, anti-bribery due diligence, risk assessments, internal investigations, and mitigation strategies across high-risk jurisdictions.

• Conducted a bribery risk controls gap analysis for a global pharmaceutical company.
• Advised a global organisation in relation to corrupt practices in its business operations in China.
• Appeared as an advocate defending companies and individuals facing serious criminal charges, including complex fraud, bribery and corruption.

Jonathan advises life sciences clients on investigations, financial crime, ESG compliance and supply-chain risks, and anti-bribery law.

• Designed a compliance programme for a global chemical company with operations in high-risk jurisdictions in the Middle East and Asia.
• Advised a global medical devices company on post-diligence mitigation approach and strategy in its China business.
• Conducted internal investigations into bribery allegations across several high-risk jurisdictions.
• Advised on managing conflicts of interest in relation to interactions with HCPs and government officials.
• Instructed by a UK pharmaceutical manufacturer and its shareholders in relation to breaches of UK export controls over a significant period of time

Jonathan advises global retailers on ESG supply chains, bribery, modern slavery and EUDR risks, including designing due diligence procedures, conducting risk assessments, and delivering proportionate mitigation strategies across high-risk jurisdictions.

• Designed a third-party due diligence procedure for a global retail company.
• Conducted a bribery risk assessment across global operations in high-risk jurisdictions.
• Conducted a modern slavery risk assessment focused on Asia-based operations.
• Advised a leading retailer on proportionate due diligence procedures and red flag mitigation.
• Advised a global food and drink manufacturer in conducting a risk assessment in preparation for compliance with the EUDR and the Environment Act 2021. This risk management expertise was delivered in collaboration with colleagues who were focused on technical considerations.
• EUDR supply chain risk – conducted country-specific analysis (People’s Republic of China) and provided advice to a global food and drink company in relation to measures required to mitigate the challenges of obtaining accurate and complete information from this jurisdiction.

Jonathan advises sports clubs and agencies on bribery, racism, tax and governance risks, including independent investigations, compliance policies, risk assessments and strategies for complex sports representation and player–agent arrangements.

• Instructed by a leading cricket club to conduct an independent investigation into allegations of racism and institutional racism raised by a former player.
• Conducted internal investigations in relation to football agency arrangements.
• Conducted a corporate tax offence advisory and risk assessment for multi-jurisdiction football representation agreements.
• Designed compliance policies for a football club.
• Advised on bribery risks involving complex structures for payments to player agents.

Jonathan advises listed and private professional practices on bribery, corruption, AML, fraud and tax evasion, leading investigations, compliance audits, supply-chain reviews, and represents clients in regulatory, enforcement, and criminal proceedings globally.

• Advised a FTSE 100 company on managing anti-tax evasion risk in order to comply with the Criminal Finances Act.
• Advised a NYSE-listed company on an internal investigation and on self-reporting obligations under the Proceeds of Crime Act 2002.
• Instructed to represent clients in their dealings with Companies House following a threat of criminal prosecution against the companies and their Directors following late filing of accounts
• Instructed to advise a UK company in relation to AML risks associated with their exposure to Norway and Sweden supply chains of a heavily regulated product
• Advised a global multinational on Risk and Compliance and Financial Crime Matters, in particular, on financial crime risks associated with the inadvertent retention of funds
• Acting for an EU-headquartered global engineering and manufacturing group. We are instructed to conduct an internal investigation following bribery allegations in relation to the company’s Chinese operations.
• Acting for a music group in respect of a Metropolitan Police investigation into Gross Negligence Manslaughter and Corporate Manslaughter following the death of two customers and serious injuries.

Jonathan advises listed and private professional practices on bribery, corruption, AML, fraud and tax evasion, leading investigations, compliance audits, supply-chain reviews, and represents clients in regulatory, enforcement, and criminal proceedings globally.

• Advised a FTSE 100 company on managing anti-tax evasion risk in order to comply with the Criminal Finances Act.
• Advised a NYSE-listed company on an internal investigation and on self-reporting obligations under the Proceeds of Crime Act 2002.
• Instructed to represent clients in their dealings with Companies House following a threat of criminal prosecution against the companies and their Directors following late filing of accounts
• Instructed to advise a UK company in relation to AML risks associated with their exposure to Norway and Sweden supply chains of a heavily regulated product
• Advised a global multinational on Risk and Compliance and Financial Crime Matters, in particular, on financial crime risks associated with the inadvertent retention of funds
• Acting for an EU-headquartered global engineering and manufacturing group. We are instructed to conduct an internal investigation following bribery allegations in relation to the company’s Chinese operations.
• Acting for a music group in respect of a Metropolitan Police investigation into Gross Negligence Manslaughter and Corporate Manslaughter following the death of two customers and serious injuries.

Recognised by The Legal 500 for Risk Advisory: Corporate Governance 2024

Recognised by The Legal 500 Regulatory Investigations and Corporate Crime (Advice to Corporates) 2023–2024

Member of the Fraud Lawyers Association