Jonathan specialises in internal investigations, financial crime, ESG compliance and supply chain risk management, whilst also being a highly regarded anti-bribery and corruption risk expert.
Jonathan has implemented business integrity programmes for companies under regulatory scrutiny from the US and UK authorities. His expertise extends to advising on sanctions, anti-money laundering, anti-tax evasion, modern slavery and broader reputational risk.
Jonathan advises across a multitude of jurisdictions including the United Arab Emirates, China, Cambodia, Italy, Ukraine, Slovakia, Nigeria, South Africa, Vietnam, Poland, Kenya, Cameroon and Ivory Coast, designing risk control frameworks, conducting in-market compliance assessments and internal investigations, and advising on risk mitigation.
Expertise
- Conduct of internal investigations for corporate clients
- Financial crime advisory
- ESG Reporting including CSRD, CSDDD and EUDR compliance
- Supply chain risk management
- Fraud and corruption investigations
- Compliance health checks and reviews
- Due diligence investigations and advice
- Modern slavery
- Reputational risks
- Sanctions
- Asset Freezing Orders
Experience
Healthcare and Life Sciences
- 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 a bribery risk controls gap analysis for a global pharmaceutical company.
- 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
- Instructed by a global pharma group to review and analyse the company’s UK third-party supplier oversight and bribery and corruption compliance programmes
Retail
- Conducted a global ESG supply chain review for a US-listed retail company with a large global footprint.
- 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.
Sport
- 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.
Professional Practices
- Advised a global organisation in relation to corrupt practices in its business operations in China.
- 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.
- Led forced labour supply chain audits for companies across several jurisdictions.
- Appeared as an advocate defending companies and individuals facing serious criminal charges, including complex fraud, bribery and corruption.
- 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
- Instructed by an Emerging Markets development finance fund to conduct two internal investigations following allegations of financial wrongdoing in relation to public infrastructure projects
- 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
Recognition
Recommended by The Legal 500 2024 for Risk Advisory: Corporate Governance
“Recommended for ESG compliance and supply chain risk management, as well as anti-bribery and corruption issues.” The Legal 500 2024
Legal 500 2024 Regulatory Investigations and Corporate Crime (Advice to Corporates)
“Jonathan Chibafa is knowledgeable on ESG compliance and supply chain risk management.” The Legal 500 2024
Recommended by The Legal 500 2023 for Regulatory Investigations and Corporate Crime (Advice to Corporates)
“Highly experienced at dealing with complex investigations. Able to think laterally and understand the nuances of complex investigations. His background as a barrister gives him a real edge in understanding the core issues at play.” The Legal 500 2023
“Jonathan Chibafa is a superstar in the team. He is bright, approachable, always available at short notice, and understanding of the pressures of our business. His advice is always practical and makes sense to the team. I never need to translate it into a simpler form for non-lawyers – it is always presented in a way that means the whole business can understand the advice and why we have got to that conclusion.” The Legal 500 2023
“Jonathan Chibafa has a varied background, which makes him very well-informed from multiple perspectives. His strategic judgment and legal knowledge was honed over nearly 10 years of independent practice at the Bar. His time in-house at large multinational corporations gives him a keen understanding of what clients need and want. He has a broad perspective that encompasses regulatory risk and compliance practice.” The Legal 500 2023
Member of the Fraud Lawyers Association
Career
Jonathan qualified as a barrister in 2006. Prior to joining Keystone Law in 2024, he worked at the following firms:
- Squire Patton Boggs
- GSK
- Allen and Overy
- Red Lion Chambers