Overview
Jonathan Drimmer is a partner in Steptoe's Washington, DC office, where he resolves complex cross-border challenges with the benefit of having sat in every chair at the table: senior legal officer for a Global 500 company, federal prosecutor, and seasoned advocate. He is ranked Band 1 by Chambers Global for business and human rights law and is widely regarded as one of the world’s leading authorities in the field. For more than two decades, he has advised and represented a wide range of companies and individuals on anti-corruption matters. His practice spans the full life cycle for both topics, including developing compliance programs, conducting investigations, and representing clients in enforcement proceedings and disputes.
Over the span of 30 years, Jonathan has directed hundreds of investigations worldwide, encompassing a vast span of geographies and substantive issues. He has represented companies and individuals in high-profile civil and criminal proceedings related to the Foreign Corrupt Practices Act (FCPA) and other anti-bribery laws, the Uyghur Forced Labor Prevention Act (UFPLA), the US Tariff Act and other laws banning forced labor imports, the Trafficking Victims Protections Reauthorization Act (TVPRA) and other anti-trafficking laws, the Alien Tort Statute, and similar matters. Jonathan has handled class actions in the US, Canada, and abroad, dealing with transnational torts, environmental cases, land controversies, and a variety of other similar areas. He has repeatedly represented companies and witnesses in congressional and parliamentary hearings related to human rights and anti-corruption issues.
Jonathan also has wide-ranging experience in helping companies manage multi-faceted dilemmas in overseas activities, developing and managing solutions that may encompass civil, criminal, regulatory, and political dimensions. He has designed a variety of human rights remedy programs and is particularly experienced in representing companies in non-judicial and quasi-judicial legal proceedings involving human rights and transnational torts. This includes disputes before the OECD National Contact Point disputes, claims to international human rights commissions, and inquiries by UN offices and agencies. He also has served as an expert witness in cases related to anti-corruption and business and human rights and has been appointed as an independent monitor or independent reviewer by companies and the UN on multiple occasions, particularly in relation to human rights and anti-corruption issues. Jonathan also has significant experience in assisting companies in developing best-in-class anti-corruption and human rights compliance programs, which include policies and procedures, training, due diligence, governance and all other program components.
He is a member of the US Federal Advisory Committee for Responsible Business Conduct, a senior advisor at BSR, the North American advisor to the Global Business Initiative on Business and Human Rights, and a strategic advisor to the secretariat for the Voluntary Principles on Security and Human Rights. Throughout his career, he has received numerous accolades and recognitions, including recognition as a Regulatory and Compliance Trailblazer and one of the 100 most influential in-house counsel in the US and Canada.
Previously, Jonathan served in the Justice Department as deputy director of the Criminal Division's Office of Special Investigations, where he led cross-border investigations, first-chaired prosecutions, and argued federal appeals. He was a partner at Am Law 100 law firms in Washington, DC, served as a Bristow Fellow in the Office of the US Solicitor General, and worked as a judicial clerk on the US Court of Appeals for the Ninth Circuit. His past board memberships include the Voluntary Principles on Security and Human Rights Initiative and TRACE International.
Jonathan was also the former deputy general counsel and chief compliance officer at Barrick Gold, one of the world's largest mining companies. He developed a compliance program at Barrick that has become an industry standard and has been replicated by numerous companies within and outside the extractive sector. Aspects of this program were the subject of a 2016 Harvard Business School case study.
- District of Columbia
- J.D., University of California, Los Angeles School of Law, 1993
- B.A., Stanford University, 1990
Areas of Work
Representative Matters
- Represented Peru’s state-owned oil company in FCPA investigation arising from oil purchases from Petroecuador.
- Represented global life sciences company in DOJ and SEC investigations under the FCPA, resulting in declination from both agencies.
- Conducted FCPA investigation on behalf of ecommerce company regarding activities in Mexico.
- Conducted FCPA investigation for global mining company regarding customs related matters in Africa.
- Conducted anti-corruption and fraud risk assessment for mid-tier mining company in Peru.
- Conducted post-diligence anti-corruption risk assessment for global copper mining company in Brazil.
- Appointed Independent Monitor for mine in Zambia, agricultural plantations in Malawi and Kenya, following UK legal settlements.
- Appointed independent expert by UN to review and report on anti-corruption, sexual exploitation, fraud and conflict of interest programs for multiple companies as part of procurement reinstatement applications following debarment related to Oil-For-Food determinations.
- Represented agricultural company in seeking exemption to withhold release order under Section 307 of Tariff Act of 1930.
- Assisted in representing technology company in Congressional investigation into allegations regarding facilitating trafficking.
- Assisted technology company in threatened litigation connected to trafficking allegations of trafficking, pursuant to state deceptive trade and marketing law.
- Assisted major global financial services in joint FCPA and UK Bribery Act investigation, and collateral civil litigation.
- Advised Fortune 100 industrial products company on double materiality assessment under the Corporate Sustainability Reporting Directive, and on reporting under California climate change-related laws.
- Advised major agricultural company on human rights program development (including developing a human rights policy framework and third party due diligence framework), compliance with EU Deforestation Regulation, and assistance in contractual negotiations regarding human rights.
- Represented global cell phone company in obtaining voluntary dismissal under Alien Tort State.
- Advised senior global mining company on gap assessment under EU Corporate Sustainability Due Diligence Directive.
- Advised major pharmaceutical company on compliance with EU Corporate Sustainability Due Diligence Directive, Corporate Sustainability reporting Directive, German Supply Chain Act, Norwegian Transparency Act, and Swiss conflict minerals and child labor ordinance.
- Advised regional internet company in connection with privacy, land, and forced labor (including forced labor import bans), government interactions and legislation, and developing of human rights program.
- Assisted major religious institution in defense of labor trafficking claims, including developing supporting compliance program.
- Represented major global consumer products company in negotiating and implementing legal settlement connected with class action in Asia.
- Advised global defense company in developing downstream human rights due diligence strategy, encompassing contractual terms, monitoring and other areas.
- Advised major confectionary company on all aspects of human rights program development and EU-related regulatory interpretations.
- Advised companies across multiple sectors on compliance with domestic human rights laws, including modern slavery acts, and the German, Norwegian and French mandatory diligence laws.
- Assisted major energy company in reviewing and revising human rights strategy, including policy development and framework, as well as investments in renewable energy.
- Represented and advised technology company surrounding allegations of doing business in Occupied Palestinian Territories in contravention of international law.
- Advised Fortune 50 technology company on assisting in developing human rights program and governance model, overseeing, reviewing and advising on human rights impact assessments, assistance in OECD NCP Specific Instance, advising on potential human rights litigation risks, advice related to EU Digital Services Act, assistance in contractual negotiations regarding human rights provisions, and conducting ESG and human rights related due diligence on business partners and developing mitigation and integration plans.
- Conducted investigation for major global mining company on sexual assault and security-related abuses in Africa and South Pacific.
- Representation and advice for major global ICT company in connection with testimony before Congressional Committee in connection with China operations, supply chains and Olympic sponsorships, as well as responding to information requests.
- Representation and counseling of witness for mid-tier mining company in connection with Parliamentary hearing in Canada regarding human rights questions at overseas gold mine.
- Representation and counseling of witness for global technology company in connection. with EU hearing related to surveillance activities, as well as representation before US executive agencies and Congress.
- Conducted investigation on behalf of senior global mining company in relation to security and human rights issue, involving use of force, right to privacy, and compelled testimony, in Asia.
- Advised senior oil company on human rights legislation, trends, and NGO campaigns.
- Provided advice to global drilling and manufacturing company regarding structure and content of global human rights program.
- Oversaw gap assessment under the Corporate Sustainability Due Diligence Directive for global ecommerce company.
News & Publications
Events
Webinars
EU Omnibus Proposal: Proposed Changes to the Sustainability Requirements
March 27, 2025
Speakers: Ruxandra Cana, Jonathan C. Drimmer, Eléonore Mullier
Noteworthy
- Chambers Global Market Leaders, Business & Human Rights Law, Band 1 (2021-2025)
- Legal 500, One of the 100 most influential in-house counsel in the US and Canada (2016)
- National Law Journal, Regulatory and Compliance Trailblazer (2015)
- Charles Fahy Distinguished Adjunct Professor Award, Georgetown University Law Center (2010)
- US Department of Justice, Assistant Attorney General Award for Human Rights Law Enforcement (2008)
- US Department of Justice, Assistant Attorney General Award, Outstanding Contribution by New Employee (2002)
- US Department of Justice, Attorney General Merit Achievement Award, Criminal Division (1999-2001, 2003)
- Legal Era, One of the top 100 in-house counsel in the world (2018)
- Ethisphere Magazine, one of the world’s leading attorneys in Ethics & Compliance (2014, 2015, 2016)
- JD Jungle, One of the top 4 lawyers under 35 years old (2001)
Authored Articles
- “Good Governance and the Future Scope of Human Rights Due Diligence,” JD Supra, November 2023
- “The Evolving Role of Boards of Directors Regarding Business and Human Rights,” Lexology, August 2023
- “Multi-stakeholder initiatives and mandatory due diligence,” Lexology, June 2023
- “Corporate Sustainability Due Diligence in the EU: Latest Updates and What to Expect Next,” Lexology, May 2023
- “Human Rights Risks for Mining and Manufacturing: Lessons from Ten Years of the OECD Guidelines,” JD Supra, April 2023
- “Don’t be Afraid of Mandatory Human Rights Due Diligence in the EU … It’s Already Here,” JD Supra, April 2023
- “New Emphasis on Human Rights and Human Rights Due Diligence in U.S. Export Controls,” JD Supra, April 2023
- “Human Rights Risks for the Financial Sector: Lessons from Ten Years of the OECD Guidelines,” JD Supra, March 2023
- “Norway and the Right to Information Under Human Rights Principles,”Lexology, February 2023
- “Downstream Due Diligence: Regulation through Litigation,” Lexology, December 2022
- “Five Business and Human Rights Sleeper Issues,” Lexology, June 2022
- “The Integration of Business and Human Rights into International Regulatory Compliance,” Lexology (six part series), December 2020 – December 2021
- “Business and Human Rights Diligence Becoming a Business Imperative,” September 2021
- “Responsible Product Usage Risk Factors Ahead of the EU Corporate Accountability and Due Diligence Directive,” March 2021
- “The Inter-American Court of Human Rights and the Gig Economy,” Lexology, February 2021
- “Responsible Product Usage,” Lexology, February 2021
- “Update to the EU Corporate Due Diligence and Corporate Accountability Initiative: The Provisional Draft and the 10 Questions Businesses Still Need to Know,” Lexology, February 2021
- “Seven Questions to Help Determine When a Company Should Remedy Human Rights Harm Under the UNGPs,” BSR White Paper, January 2021
- “Pre-Draft of the EU Mandatory Corporate Due Diligence and Corporate Accountability Initiative: 10 Questions Businesses Need to Know,” Lexology, October 2020
- “How a Biden Administration May Approach Business and Human Rights,” Lexology, August 2020
- “Due Diligence and The Business & Human Rights Treaty,” August 2020
- “Draft Business and Human Rights Treaty, Take 3,” Lexology, August 2020
- “Human Rights Diligence Catching up to Anti-Corruption,” Lexology, June 2020
- “The Growing Importance of ESG Due Diligence Post-COVID-19,” TRACE White Paper, June 2020
- “Human Rights Are Becoming a Compliance Issue,” Law360, May 2020
- “Leveraging Anti-Bribery Compliance Programs to Address Human Rights in a Post-COVID-19 World,” TRACE White Paper, April 2020
- “ESG Strategies Could Be Misleading Investors,” Lexology, March 2020
- “After Covid-19: My roadmap to a cost-effective human rights compliance program,” FCPA Blog, April 2020
- “How Corporate Sustainability Creates Legal Risk,” Yahoo Finance, February 2020
- "Five Steps for Companies Facing an OECD National Contact Point Process," Anti-Corruption Report, December 2019
- "ESG and Mission-Critical Issues for Director & Officer Liability," Corp Gov, December 2019
- "Behavioral Ethics and Economics, Compliance Culture and Meeting DOJ’s Compliance Expectations," Anti-Corruption Report, June-July 2019
- "Doing Business in Argentina after the Notebooks Scandal," Anti-Corruption Report, March 2019
- "FCPA Compliance: The Role of Data Collection & Analysis," Securities & Commodities Regulation, May 2018
- "OECD Guidelines for Responsible Business Conduct & Sector Specific Guidance: A Manual for Canada," Global Compact Network Canada, April 2018
- "Developing KPIs and Tracking Metrics Using ISO 37001," 5 FCPA Report 22, November-December 2016 (two part article)
- "Children’s Rights and Security Checklist and Handbook," UNICEF, 2017, 2018
- "A Guidance Document to Assist Companies Assess and Manage Corruption Risk," Global Compact Network Canada, 2016
- "Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Compliance Program," 5 FCPA Report No. 4-5, February-March 2016
- "Auditing Implementation of Voluntary Principles on Security and Human Rights: A Guidance Document to Assist Companies and their Auditors Assess Implementation of the Voluntary Principles on Security and Human Rights," Global Compact Network Canada, 2015
- "The Third Pillar: Remedies, Reparations and the Ruggie Principles," in The Business and Human Rights Landscape (Cambridge Univ. Press 2015, K. Bravo & J. Martin eds.)
- "Does the Hand Fit the Glove?: Assessing your Company’s Anti-Corruption Compliance Program," ACC Docket, June 2013
- "Kiobel and the Guiding Principles on Business and Human Rights," ACC Docket, June 2012
- "Think Globally, Sue Locally: Trends and Out-of-Court Tactics in Transnational Tort Actions," 29 Berk. J. Int’l L. 456, 2011
- "Think Globally, Sue Locally," Wall Street Journal, June 2010
- "Emerging Risk," Private Equity Manager Monthly, February 2010
- "Is Second Circuit Ruling a 'Talisman' Against Alien Tort Statute Suits?" Washington Legal Foundation Legal Backgrounder, February 2010
- "New Costs of Doing Business Abroad," L.A. Daily Journal, December 2009
- "Specific Corporate Compliance Challenges: Extractive Industry," in Corporate Compliance Practice Guide: The Next Generation of Compliance (Carol Basri, ed.), October 2009
Professional Affiliations
- US Federal Advisory Committee for Responsible Business Conduct, 2023-2025
- World Economic Forum, Global Future Council on the Future of Good Governance, 2022-2024
- Advisor, The Global Sustainability Standards Board, 2023-2025
- Member, OECD Expert Group on Preventing Corruption in Transition Minerals, 2022-2025
- Board of Directors, Fund for Peace, 2019
- Board of Directors, Trees for the Future, 2020-2025
- Board of Directors, International Data Center Association, 2023-2025
- Board of Directors, Trace International, 2012-2018
- Board of Directors, Trace Foundation, 2018-2025
- Subject Expert, Canadian Centre of Excellence for Anti-Corruption, 2017-2025
- External Human Rights Advisory Board, JTI, 2019-2025
- Board of Directors, Global Compact Network Canada, 2013-2021
- Board of Directors, Voluntary Principles on Security and Human Rights, 2012-14, 2016-2018
- Board of Directors, Transparency International Canada, 2019-2021
- US OECD National Contact Point, External Stakeholder Advisory Board, 2018-2021
- Member, ANSI US Technical Advisory Group for ISO on anti-bribery compliance, 2015-2016
- Steering Committee Member, UN Global Compact Business for Peace Initiative, 2014-2021
- Adjunct Professor, Georgetown University Law Center, 2000-2025