Jason S.Varnado


Houston + 1.832.239.3694

Jason Varnado is an experienced trial lawyer and the head of litigation for the Houston Office. His practice involves representing businesses and individuals during investigations by federal and state governmental authorities for potential criminal charges; actively litigating criminal and civil actions on behalf of clients facing allegations of fraud, false claims, and other business-related wrongdoing; and advising corporate clients regarding compliance issues to avoid governmental sanctions.

Since joining Jones Day, Jason has served as lead investigative and defense counsel in numerous high-profile criminal and civil matters involving alleged violations of the Foreign Corrupt Practices Act (FCPA), the Controlled Substances Act (CSA), the False Claims Act (FCA), the Anti-Kickback Statute (AKS), and the Clean Air Act (CAA). He has also represented business and individuals accused of federal campaign contribution violations, economic espionage, and federal income tax offenses.

Before joining Jones Day, Jason served with the U.S. Department of Justice (DOJ) for 10 years in several top-level positions. He tried 15 federal criminal cases to verdict, including one of the few cases under the FCPA ever to be tried to a jury, and was awarded U.S. Attorney General's "John Marshall Award" for Outstanding Achievement in Litigation, the Department's highest award for legal performance in a specialized area.

Jason has been recognized by numerous publications, including Chambers USA, Best Lawyers in America, Super Lawyers, and Houstonia magazine.


  • Marubeni sells global grain business of Gavilon Agriculture InvestmentJones Day advised Marubeni Corporation in the sale of the global grain business of Gavilon Agriculture Investment, Inc. to Viterra Limited, following a reorganization of Gavilon’s structure.
  • Pharmaceutical manufacturer successfully defends False Claims Act caseJones Day represented a pharmaceutical manufacturer as a defendant in a False Claims Act case alleging off-label marketing, among other things.
  • Robert Brockman defends $2 billion tax fraud case brought by DOJJones Day represents Robert Brockman, former CEO of a software company, in what the DOJ has described as the largest tax fraud case ever charged against an individual.
  • alliantgroup LP obtains dismissal of Universities' RICO claimsOn behalf of alliantgroup LP, Jones Day obtained the dismissal of all claims brought in the second amended complaint in The University of Texas System, et. al. v. alliantgroup LP, et. al., No. 4:17-cv-02588 (S.D. Texas).
  • Flowchem acquired by KMG for $495 millionJones Day advised Flowchem LLC, a portfolio company of Arsenal Capital Partners, in its $495 million acquisition by KMG Chemicals, a leading global provider of specialty chemicals.
  • 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).

    Speaking Engagements

    • 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"

    September, 2015

    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"

    Houston, Texas

    September, 2015

    5th Annual Gulf Coast Anti-Money Laundering Forum, Keynote Address, "Prosecution of White Collar Crime Post-Financial Crisis"

    Houston, Texas

    August 2015

    FBI Compliance Round Table, "Federal Prosecution of Corporate Espionage and Data Breach Cases"

    Houston, TX

    May, 2015

    2015 University of Texas School of Law’s Government Enforcement Institute, Panelist, “Accounting and Securities Fraud”

    Dallas, Texas

    March, 2015

    21st FBI Financial Institution Crime Day Houston, “Bank Fraud Update from the U.S. Department of Justice”

    Houston, Texas

    February, 2015

    Houston Director's Roundtable, Panelist, “Key Issues Facing Boards of Directors: New Enforcement Initiatives and Corporate Governance Rules” 

    Houston, Texas

    January, 2015

    American Conference Institute’s 9th FCPA Boot Camp, “What the Government Expects to See in Your Anti-Corruption Compliance Program”

    Houston, Texas

    September, 2014

    Momentum’s 2nd Annual Oil & Gas Anti-Corruption Compliance Exchange, “Compliance Perspective from the U.S. Department of Justice”

    Houston, Texas

    June, 2014

    FBI Financial Institution Fraud Unit, Advanced Mortgage Fraud Conference, Mortgage Fraud, “A Prosecutorial Perspective Five Years After the Financial Crisis” 

    Washington, DC

    March, 2014

    BITS Financial Services Roundtable, “Current Bank Fraud and Mortgage Fraud Perspective from the U.S. Department of Justice”

    Washington, DC

    November, 2013

    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”

    Washington, DC