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Jason Gray



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Jason Gray



For over 20 years Jason has advised individuals and companies in complex white-collar crime matters and civil enforcement proceedings, government inquiries, cross-border and regulatory investigations and related litigation.

His practice has an emphasis on defense of clients before government agencies as well as the conduct of proactive compliance reviews and internal investigations related to anti-bribery and corruption, economic sanctions, money laundering, modern slavery, corporate fraud, financial services misconduct and related matters.

A particular focus of much of Jason’s work is compliance with anti-bribery and corruption laws. He co-leads Allen & Overy’s U.S. Foreign Corrupt Practices Act (FCPA) team throughout Asia-Pacific. His experience under the FCPA, UK Bribery Act, Australian Criminal Code and related laws includes investigations throughout Asia, Africa and South America, the development and implementation of compliance programs, policies and structures designed to prevent and detect potential violations of law, as well as conducting compliance due diligence in connection with corporate transactions.

Jason is also regularly involved in advising company boards and audit committees with respect to the many complicated issues that can arise in internal investigations, including consideration of disclosure to government and responding to whistle-blower complaints, as well as addressing cross-border discovery, privilege and data privacy issues.

Jason is consistently recognized as a leading individual in both Chambers & Partners and Legal 500 for White Collar Crime and Corporate Investigations in Australia. He wins high praise from clients as being “extremely responsive” and “focused on client needs”, as well as being able to combine “deep substantive knowledge with a pragmatism" that is particularly helpful in planning and conducting investigations.

Jason joined Allen & Overy from the New York office of a U.S.-headquartered global law firm where he was a counsel in the white-collar crime and government enforcement practice group of that firm. Jason has also spent time as an enforcement attorney at a corporate and markets regulator and at the beginning of his legal career clerked for the Chief Justice of the Federal Court.

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Experience highlights



Level 25, 85 Castlereagh Street
NSW 2000

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Admitted as a solicitor in New South Wales, 2002

Admitted to practise in New York State, Southern District of New York and Eastern District of New York

Admitted in the U.S. Court of Appeals for the Ninth Circuit


Bachelor of Arts (First Class Honours and University Medal), University of Sydney, 1998

LL.B (First Class Honours), University of Sydney, 2000

LL.M, Harvard Law School, 2002

Other noteworthy experience

  • Represented a national sporting federation in regarding allegations of bribery and corruption in relation to the sports global governing body.
  • Extensive experience conducting pre-investment and pre-acquisition compliance due diligence (FCPA/ABC, AML and sanctions) in numerous multi-billion dollar deals in Africa, Asia Pacific, and Latin America.
  • Assisting numerous companies, from start-ups to Fortune 50 corporations, with developing codes of conduct and compliance procedures, conducting risk assessments, gap analysis and compliance benchmarking, and enhancing compliance programs.
  • Jason has been a guest lecturer at several universities, covering topics such as anti-money laundering, corporate law, torts, and contracts.

Published work

  • Jason Gray, et. al., "Anti-Bribery and Corruption Year in Review: 2018", February 1, 2019.
  • Jason Gray, et. al., "Modern Slavery: Preparing for Greater Supply Chain Transparency", September 3, 2018.
  • Jason Gray, et. al., "Significant Changes on the Horizon for Australia's Anti-Bribery and Corruption Framework", Marsh 21, 2018, The Anti-Corruption Report (
  • Jason Gray, et. al., "China’s new anti-bribery agency announces pharma probe", May 24, 2018.