Jonathan is the firm leader of the global fraud and forensic investigations and compliance practice. He has more than 30 years of experience working closely with his clients, their board, senior management and law firms on global and cross-border fraud and misconduct investigations, including bribery, corruption and compliance matters.
Jonathan specializes in internal and regulatory investigations; governance matters; risk assessment, design and implementation of compliance programs; global fraud risk management programs; and compliance coordination and monitoring services for the private, public, not-for-profit sectors. He assists his clients to mitigate potential issues by conducting root-cause analysis, developing remedial procedures, and designing or enhancing governance and compliance systems along with internal controls, policies and procedures and customized training.
He has led high-profile financial, accounting, compliance and regulatory investigations around the world relating to allegations of accounting irregularities, improper financial disclosures, fraud, noncompliance, bribery, corruption, money laundering, kickbacks, cyber incidents and whistleblower matters. Jonathan has provided expert testimony on accounting, financial, and internal control issues in commercial litigation matters. He has appeared before the United States Securities and Exchange Commission (SEC), Financial Industry Regulation Authority (FINRA), and the United States Department of Justice (DOJ) to present his findings. Jonathan has also led global compliance initiatives, fraud risk or vulnerability assessments, internal audits, and third-party risk management programs.
Jonathan is a well-regarded author and speaker, who has gained international recognition for developing thought leadership that has enhanced the profession. He presents regularly on an array of fraud, ethics, and forensic accounting topics. He was an adjunct professor at Rider University and today is a guest lecturer at Lehigh University. Jonathan has previously held leadership positions at a national accounting and a global disputes and investigations professional services firm. He has educated and advised some of the world’s largest companies on these and a variety of other highly complex issues.
- Led a 10A investigation that involved several complex issues, including alleged illegal acts related to the valuation of inventory, inventory reserves. Non-GAAP financial information, and the overall completeness and accuracy of the books and records; worked closely with outside counsel and the external auditor, including their national practice leaders and forensic group
- Led several large global FCPA investigations and compliance exercises, working with management, outside counsel and in some instances the external auditor
- Developed a road map, synthesized huge amounts of data with more than 15 organizations, and prepared an analysis to assist counsel in the defense of an alleged stock manipulator; analysis and findings were presented to the U.S. Attorney, FBI, SEC and FINRA, who accepted and commented on quality and thoroughness of the work product
- Conducted numerous fraud and FCPA risk assessments for many companies in many different industries, including a Fortune Five company; assisted with the development of the compliance program and the development or enhancement of internal controls, policies and procedures, and training
- Engaged by the president, general counsel, and chief compliance officer of a Forbes Top 50 manufacturer and distributor to conduct a pre-monitor review focusing on assess its governance, risk management and compliance program. I then served as the compliance coordinator and liaison between the company and the DOJ’s monitor and assisted the company with its remediation and training efforts. Led an internal audit team of more than 25 professionals in conducting on-site reviews of more than 360 distributors nationwide, the results of which helped enhance the control environment and compliance program
- Provided forensic accounting support to counsel to two senior executives (chief executive officer and chief financial officer) that were subjects of an SEC investigation related to revenue recognition issues
- Managed a special audit committee investigation for a Forbes Top 100 company that spanned many countries and involved performing root cause analysis related to alleged $400 million fraud related to channel stuffing by a large pharmaceutical concern. The investigation uncovered deficiencies in the overall governance framework, and legal, compliance, and internal audit functions. Subsequent to the investigation, Jonathan was retained to assist with the remediation of the legal, compliance, and internal audit functions. He also led a team to evaluate and enhance the design of internal controls.
- Engaged by the audit committee of a Fortune 50 company to perform a root cause analysis and provide an assessment to the full board on the results of a massive internal investigation related to alleged revenue recognition issues brought forward by a whistleblower; initial investigation was conducted by a highly reputable law firm which was assisted by a Big 4 accounting firm; Jonathan assisted in drafting the report, which provided recommendations on improving governance, risk, compliance and internal controls
- Led the investigation of allegations that the chief executive officer, chief financial officer and controller of large professional services firm knowingly departed from generally accepted accounting principles (GAAP) and SEC guidance when recording revenue; presented findings and conclusions to the national office of the auditing firm, which concurred with assessment on the application of GAAP, resulting in others within the same space restating their financial statements
- Helped lead an investigation related to millions of leaked documents that detail financial and attorney-client information for hundreds of thousands off-shore entities; provided guidance on possible bribery, money laundering and tax avoidance schemes
- Retained by outside counsel to investigate allegations from a whistleblower that the general counsel and the controller were engaged in several schemes to defraud a large hospital group; the investigation uncovered an enormous fraud and many internal controls deficiencies, including weaknesses in governance, the risk assessment process and internal audit plan
- Worked directly with the US Attorney, FBI, IRS-CID and US Customs on a highly-publicized investigation involving a myriad of fraud schemes, concealment strategies and conversion tactics that involved individuals and both private and publicly held companies
- Presented, “Financial Reporting Fraud: White Collar Crime”
- Co-authored “Whistleblowers: Trust the Process,” Fraud Magazine
- Co-authored “The Triangle of Fraud Action: A Response to the Fraud Triangle on Trial”
- Co-authored “Not an Aberration—Creating a Risk of Bribery Might Be Enough!,” The Legal Intelligencer
- Co-authored “Calculating the Correct Tax Loss: Are You Looking 'Outside the Box,’” The Legal Intelligencer
- Co-authored “Responding to Whistleblowers: A Structured Triage Approach is Essential”
- Co-authored “Surviving a Restatement: Ten Pitfalls to Avoid,” NACD
- Co-authored “Beyond the FCPA: Strong internal controls and effective internal audit are critical factors in global anticorruption efforts,” Internal Auditor Magazine
- American Bar Association (ABA), previously served on the Professional Services Liability Committee Member
- American Institute of Certified Public Accountants (AICPA)
- Association of Certified Fraud Examiners (ACFE)
- FBI National Citizens Academy, Philadelphia Chapter board member and Audit Committee chairperson
- Financial Executives International (FEI), Research Committee member
- Former adjunct professor at Rider University
- Guest lecturer at Lehigh University
- InfraGard, member
- Institute for Fraud Prevention (IFP), Intellectual Board member
- International Association of Independent Corporate Monitors
- National Association of Corporate Directors (NACD), board fellow
- Pennsylvania Institute of Certified Public Accountants (PICPA)
- Society of Corporate Compliance and Ethics (SCCE)
- Cancer Support Community of Philadelphia, Gilda’s Club, chairperson of the board
- Cancer Support Community, National Board member
- Zeta Psi, Pi Kappa Chapter, president of the Alumni Association
Location
Philadelphia, PA
Education
Bachelor of Science/Bachelor of accounting
Bloomsburg University (Bloomsburg, Pennsylvania)
