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Jason Gray



Gray Jason
Jason Gray



Jason is a partner in our Asia Pacific litigation practice. He advises 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-corruption, economic sanctions, money laundering, corporate fraud and related matters.

The focus of much of Jason’s work is compliance with anti-bribery and corruption laws (ABC). He leads Allen & Overy’s U.S. Foreign Corrupt Practices Act (FCPA) team throughout Asia-Pacific, and his experience under the FCPA, UK Bribery Act, Australian Criminal Code and related laws includes global investigations, the development of ABC compliance programs, and ABC due diligence in connection with corporate transactions.

Jason’s experience includes the conduct of investigations around the world, including throughout Asia, Africa and South America, and across numerous industries including technology, financial services, oil and gas, life sciences, food and beverage, and consumer goods. He is 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 and data privacy issues.

Jason is consistently recognized as a leading individual in Chambers & Partners for Anti-Bribery & Corruption and in Legal 500 for Regulatory Compliance and Investigations. He wins high praise from clients as an "impressive lawyer" who is "very practical" and who "combines deep substantive knowledge with a pragmatism" that is particularly helpful in planning and conducting investigations. Clients also highlight the focus and dedication of Jason and his team, noting: "We're a very happy customer - they did very good work, they were focused on our needs, very available and did very good work."

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.

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.

Experience highlights



Allen & Overy
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


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.

News & insights

Advocate General Opinion on the Sisal – Magellan Robotech Case

Publications: 05 JULY 2021

More clarity – and more questions – on Australia’s Anti-Money Laundering and Counter-Terrorism Financing Reforms

Key amendments to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws have now come into effect, alongside new rules providing clarity on those amendments and an inquiry…

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Close up of building exterior

Publications: 23 DECEMBER 2020

Australia moves – incrementally – towards AML/CTF compliance

Australia has implemented “Phase 1.5” in its anti-money laundering and counter-terrorism reforms.  However, Australia’s long-awaited and much-debated “second tranche” of reforms remains out of grasp.

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Publications: 19 AUGUST 2020

Podcast: How Covid-19 has impacted anti-bribery and corruption compliance and enforcement in Asia and Australia

Billy Jacobson speaks with Hong Kong partner Eugene Chen and Sydney partner Jason Gray about how the Covid-19 pandemic has impacted anti-bribery and corruption ( "ABC") compliance and enforcement…

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The sun shining behind a row of modern skyscrapers

Publications: 14 JULY 2020

UK “Magnitsky” sanctions: The dawning of a brave new world?

In a heavily trailed move, the UK on 6 July 2020 imposed its first so-called “Magnitsky” sanctions on entities and individuals alleged to have been involved in human rights abuses pursuant to the…

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