Jonathan Chibafa specialises in global investigations, financial crime, ESG compliance and supply chain risk management. Jonathan is also a highly regarded anti-bribery and corruption risk expert. As well as several years at a leading set of barristers’ chambers specialising in criminal and regulatory law, Jonathan has extensive industry experience having held senior compliance roles at a FTSE 100 retailer and a multinational pharmaceutical company. He has also worked as a consultant advising several Fortune 500 companies.

He 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 has worked with commercial leadership teams and compliance professionals in more than 40 countries. He has designed risk control frameworks, conducted in-market compliance assessments and advised on risk mitigation in a broad range of jurisdictions, including the United Arab Emirates, China, Cambodia, Russia, Ukraine, Slovakia, Nigeria, South Africa, Vietnam, Poland, Kenya, Cameroon and Ivory Coast.

Jonathan has been seconded to the Serious Fraud Office and the Financial Conduct Authority. Jonathan also advised the Attorney General of the Falkland Islands on compliance with OECD regulations and anti-corruption compliance. This included a period of secondment on the islands.

Jonathan combines deep subject matter expertise with years of in-house experience, allowing him to provide concise and pragmatic advice. His practical experience is balanced between remediation and preventative work.

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  • Leading an internal investigation into allegations of bribery of foreign officials across several high-risk jurisdictions.
  • Conducting a global ESG supply chain review for a US-listed retail company with a large global footprint.
  • Advising companies and company directors facing the threat of criminal prosecution from Companies House for late filings.
  • Conducting a bribery risk controls gap analysis for a global pharmaceutical company.
  • Leading forced labour supply chain audits for companies across several jurisdictions.
  • Leading an internal investigation for a global manufacturing company looking into allegations of breach of confidentiality.
  • Instructed by a leading cricket club to conduct an independent investigation into allegations of racism and institutional racism raised by a former player.
  • Conducting a sensitive workplace investigation for a global media company.
  • Appearing as an advocate defending companies and individuals facing serious criminal charges, including complex fraud, bribery and corruption.
  • Conducting a risk assessment for a global energy company with complex global operations in high-risk jurisdictions.
  • Advising a global medical devices company on post-diligence mitigation approach and strategy in its China business.
  • Advising a FTSE 100 company on managing anti-tax evasion risk in order to comply with the Criminal Finances Act.
  • Advising a NYSE-listed company on an internal investigation and on self-reporting obligations under the Proceeds of Crime Act 2002.
  • Designing a compliance programme for a global chemical company with operations in high-risk jurisdictions in the Middle East and in Asia.
  • Advising a global organisation in relation to corrupt practices in its business operations in China.

Education

  • Kingston University, LL.B., (Hons), 2003

Admissions

  • Bar Council of England and Wales, 2006

Memberships & Affiliations

  • Queen Mother Scholar, Middle Temple
  • Door Tenant, Red Lion Chambers
  • Member, Fraud Lawyers Association

Languages

  • English
  • Shona
  • Ndebele/Zulu
  • “Jonathan Chibafa is recommended for ESG compliance and supply chain risk management, as well as anti-bribery and corruption issues.” The Legal 500 2024 (Corporate Governance)
  • “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

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  • Faculty, Practicing Law Institute (PLI) Advanced Compliance and Ethics Workshop, New York, October 2023.
  • Panellist, “Managing Chinese Labor Risks”, Wall Street Journal Risk & Compliance Forum, November 2022.
  • Co-author, “ESG Enforcement Risks: From ‘Greenwashing’ to ‘Wokewashing’,” ACC Docket, July 19, 2022.
  • Co-author, “Lack of Uniformity in ESG Ratings System Poses Risks, Opportunities,” Bloomberg Law, May 16, 2022.
  • Co-author, “Securing a Resilient Supply Chain”, LexisNexis, February 2022.
  • Panellist, “ESG, identifying and managing key risks”, Practising Law Institute Advanced Compliance and Ethics Workshop, November 2021.
  • Panellist, “Third Parties: Keeping a Pulse on Misconduct Deep into the Supply Chain”, Converge 19 Europe, Brussels, May 2019.
  • Panellist, “Integrating Ethical Practices Across the Supply Chain”, Business Integrity Initiative by the British Deputy High Commission in Karachi, Webinar, July 2019.
  • Panellist, “Fighting Corruption, the Role of Internal Audit”, Internal Audit 2019, London, October 2019.
  • Panellist, “Data Driven Decisions: Using data to measure and move your compliance programme”, event organised by the Practising Law Institute, London, November 2019.
  • Panellist, “Third party risk: how do you transform compliance from a firefighting exercise into a proactive business enabler?” hosted by Compliance Week, Webcast, December 2019.
  • Author, “Corporate tax evasion: what does ‘reasonable procedures’ mean in practice?” Practical Law Blog, February 2020.
  • Moderator, “Is your Bribery Risk Management Approach Fit for Purpose?” Webinar, May 2020.
  • Panellist, “Whistleblowing, a 360° view”, Webinar organised by the Association of Corporate Investigators, July 2020.

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