Jonathan C. Poling is a partner in Akin Gump’s international trade practice. He is a former federal prosecutor with the DOJ, where he handled prosecutions relating to violations of U.S. economic sanctions, money laundering and export control laws. He has also represented companies in anti-corruption matters before the U.S. Department of Justice, Securities and Exchange Commission and before various multilateral development banks. 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.
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
- Temporary denial orders (TDOs)
- Industry outreach visits
- Entity list designations
- Corporate compliance issues.
His 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 Trading with the Enemy Act; 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 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.
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.
- Previous member of the DOJ Foreign Investment Review Staff on the Committee on Foreign investment in the United States (CFIUS).
- Practice focuses on international trade, with significant experience handling complex civil and criminal matters.
- Served as a prosecutor, U.S. Department of Justice (DOJ), National Security Division, Counterespionage Section.
- 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, U.S. Department of the Treasury’s Office of Foreign Assets Control (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.
Export Controls and Economic Sanctions:
- Defended a global manufacturing company in a sanctions and export control investigation conducted by the Federal Bureau of Investigation and BIS.
- 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.
- Defended a global technology company in a sanctions and export control investigation before the U.S. Departments of Justice, Commerce, State, Homeland Security, Treasury and Defense.
- Represented a senior executive in a Chinese company as part of an ongoing investigation by the U.S. Department of Justice, Department of Commerce’s Bureau of Industry and Security (BIS) and OFAC.
- J.D., Georgetown University Law Center, 2002
- B.A., Villanova University, summa cum laude, 1999
- District of Columbia
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