Jason Varnado is a former federal prosecutor and one of only a handful of attorneys in the United States to have tried a Foreign Corrupt Practices Act case to a jury. In addition to his work under the FCPA, he has extensive experience investigating and trying all manner of high-stakes financial fraud cases, including health care fraud, securities fraud, investment fraud, and money laundering. Jason also has significant experience litigating various cybersecurity matters ranging from violations of the Computer Fraud and Abuse Act to criminal trademark infringement and theft of trade secret actions. His practice focuses on defending individuals and corporations in criminal and regulatory proceedings, conducting internal investigations, and counseling clients on compliance programs and issues.
Prior to joining Jones Day in 2015, Jason served with the U.S. Department of Justice for 10 years in several top-level positions. During this time he was lead prosecutor in dozens of complex white collar criminal cases, tried 15 federal criminal cases to verdict, and argued multiple Fifth Circuit appeals. For example, Jason co-led the five-week jury trial that convicted the top accountants in former prominent financier Allen Stanford's $7 billion international Ponzi scheme for which he received the U.S. Attorney General's "John Marshall Award" for Outstanding Achievement in Litigation, the Department of Justice's highest award for legal performance in a specialized area.
Jason has spoken extensively both to private industry and to law enforcement on compliance and fraud-related topics.
The following represents experience acquired prior to joining Jones Day.
International discount fraud: three-week jury trial that convicted a U.K national of conspiracy and international money laundering by defrauding Hewlett-Packard of more than $20 million through straw buyers and misrepresentations concerning the end users of the company's computer equipment.
Foreign Corrupt Practices Act: one of only a handful of FCPA cases in the country to be tried before a jury against the vice president and general manager of an international energy company who allegedly paid bribes to secure a $37 million utility contract with Mexico (case ended at Rule 29 stage).
Money laundering: four-week jury trial that involved a sophisticated scheme to launder millions of dollars in drug proceeds from the U.S. to Vietnam and Canada (received FBI and IRS commendations for Complex International Prosecution).
Criminal trademark infringement: criminal trademark infringement jury trial that involved counterfeit Cisco computer parts sold by a Saudi national to the U.S. Marine Corps in Iraq (cited in Congressional testimony by the Secretary of Department of Homeland Security).
International business visa scam: two-week jury trial of corrupt business owners engaged in complex international visa scam that involved 90 foreign nationals and millions of dollars in illicit payments (received Immigration & Customs Enforcement commendation).
Immigration attorney fraud: three-week jury trial against corrupt immigration attorney and her paralegal in a scheme to fraudulently enable wealthy foreign nationals to obtain permanent legal resident status in the United States.
Health care fraud: obtained guilty verdicts after a six-week jury trial against two physicians for their $10 million scheme to defraud Medicare and Medicaid in a motorized wheelchair scam.
Energy industry fraud: prosecuted shipping manager and several co-conspirators (including former associates of Mark Rich) for international kickback scheme to defraud chemical company LyondellBasell out of $80 million related to the shipment of crude oil from Venezuela to Houston, Texas.
Investment fraud: prosecuted securities broker for defrauding investors victimized in elaborate corporate bond scheme involving $16 million in losses (subject of CNBC's American Greed, Season 8/Episode 4 (2014)).
International investigations: served as deputy international affairs coordinator for the Southern District of Texas and assisted foreign law enforcement counterparts on numerous investigations, including the United Kingdom's Serious Fraud Office in connection with the lraqi Oil for Food scandal.
Corporate embezzlement: prosecuted a Memorial Hermann Hospital employee in a 14-year false invoicing scheme to defraud the hospital out of $10 million.
Insurance fraud: prosecuted two pain management doctors for a $40 million false billing and prescription drug trafficking scheme that defrauded Medicare and 18 private insurers (received "Investigation of the Year Award" from the National Health Care Anti-Fraud Association).
Disaster relief fraud: served as the disaster assistance fraud coordinator in the Southern District of Texas and prosecuted dozens of disaster assistance fraud cases after Hurricanes Katrina and Rita, including the owner of the former Flagship Hotel on Galveston Island and individuals who defrauded Oprah Winfrey's Angel Lane housing program (received Department of Homeland Security commendation).
Evidence Collection in Criminal Investigations: Cross-Border Issues and Corporate Employee Considerations
- May 12, 2017
Client Confidentiality in the Digital Age, Texas District & County Attorneys Association
- January 12, 2017
Client Confidentiality in the Digital Age: Cybersecurity Ethics and Risk Mitigation for Lawyers, Houston Bar Association
- October 18, 2016
FCPA Investigations and the New National Anticorruption System in Mexico, speaker
- May 11, 2016
Accounting and Enforcement Update for Energy Companies
- February 2016
North Texas Ethics and Compliance Council, "The Yates Memo: What it Really Means for Compliance Officers and Corporate Counsel"
Momentum's 3rd Annual Oil & Gas Anti-Corruption & Compliance Exchange, Keynote Address, "Instituting an Effective Compliance Program: Views from the United States Attorney's Office, Southern District of Texas"
5th Annual Gulf Coast Anti-Money Laundering Forum, Keynote Address, "Prosecution of White Collar Crime Post-Financial Crisis"
FBI Compliance Round Table, "Federal Prosecution of Corporate Espionage and Data Breach Cases"
2015 University of Texas School of Law’s Government Enforcement Institute, Panelist, “Accounting and Securities Fraud”
21st FBI Financial Institution Crime Day Houston, “Bank Fraud Update from the U.S. Department of Justice”
Houston Director's Roundtable, Panelist, “Key Issues Facing Boards of Directors: New Enforcement Initiatives and Corporate Governance Rules”
American Conference Institute’s 9th FCPA Boot Camp, “What the Government Expects to See in Your Anti-Corruption Compliance Program”
Momentum’s 2nd Annual Oil & Gas Anti-Corruption Compliance Exchange, “Compliance Perspective from the U.S. Department of Justice”
FBI Financial Institution Fraud Unit, Advanced Mortgage Fraud Conference, Mortgage Fraud, “A Prosecutorial Perspective Five Years After the Financial Crisis”
BITS Financial Services Roundtable, “Current Bank Fraud and Mortgage Fraud Perspective from the U.S. Department of Justice”
American Bar Association Litigation Section, “Corporate Counsel Committee, Economic Espionage Act: Interfacing With a U.S. Attorney's Office From Theft of Trade Secret Through Sentencing”
- The University of Texas at Austin (J.D. with honors 2000; Texas Law Review); Clemson University (B.S. in Industrial Engineering magna cum laude 1996)
- Texas, California, all U.S. District Courts in Texas, and U.S. Court of Appeals for the Fifth Circuit
- Served with the U.S. Attorney's Office for the Southern District of Texas (2005-2015) in the following positions: Chief, Major Fraud Section; Senior Litigation Counsel; Assistant U.S. Attorney, Major Fraud Section; and also served at the Executive Office for United States Attorneys as the National White Collar & Cyber Crime Coordinator (2013-2014) and the National White Collar Crime Coordinator (2010-2011)