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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 identify Jason as someone who is distinguished by "his swift grasp and clear exposition of complex issues".

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

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Publications: 11 DECEMBER 2019

Australia proposes robust new foreign bribery laws

On Monday 2 December, the Australian Government introduced into the Senate the Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2019 (Cth) (“Foreign Bribery Bill”). This Bill proposes to…

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Publications: 11 NOVEMBER 2019

“Phase 1.5” in Australia’s Anti-Money Laundering and Counter-Terrorism Financing Reforms

On 17 October 2019, the Australian Government introduced a bill into Parliament to implement the next phase of reforms to the country’s anti-money laundering and counter-terrorism financing…

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Publications: 03 SEPTEMBER 2018

Modern Slavery: Preparing for Greater Supply Chain Transparency in Australia

Australia has become the latest jurisdiction to target modern slavery, with the Modern Slavery Bill 2018 (Cth) (Bill) being introduced into Federal Parliament on 28 June 2018. Modelled on the UK…

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Publications: 02 AUGUST 2018

The opportunities and challenges facing legal and compliance experts in ASEAN

Over 180 legal counsel and compliance professionals joined us recently for our inaugural “One Day Intensive” in Kuala Lumpur, where our lawyers and industry experts spoke about key developments and…

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