UK-wide - POCA Work & Asset Forfeiture Lawyers & Law Firms - UK | Chambers and Partners
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UK Guide

POCA Work & Asset Forfeiture — UK-wide


BCL Solicitors LLP - POCA Work & Asset Forfeiture

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Band 1

第一等

Commentary from the Chambers UK guide

Basic facts about the department
- 8 partners
- 1 counsel
- 13 other qualified lawyers
- Office location: London

What the team is known for Market-leading defence practice handling the full spectrum of POCA and asset forfeiture matters. Frequently assists high-profile individuals and corporate clients with anti-money laundering compliance as well as representing them in investigations and pre- and post-conviction litigation. POCA practice benefits from complementary specialisms in general crime, financial crime and tax fraud.

Strengths Sources say: "They are very knowledgeable in this area, they know their stuff. They are very practical and responsive with the other side. They communicate very well."

One commentator says: "They are the pre-eminent firm for criminal fraud work. They are thorough, very good on the law and prepare cases immaculately."

Notable practitioners

Richard Sallybanks is widely recognised as an expert in POCA work. Commentators say: "He is extremely user-friendly, brilliant at running the show and keeping everybody informed and happy." He is experienced handling domestic and international investigations with restraint, confiscation and money laundering aspects.

Shaul Brazil is a well-regarded POCA practitioner, focusing on corporate crimes and regulatory enforcement. He has experience in cross-border restraint and confiscation measures. Sources report: "He is very clever, tenacious and hard-working. He analyses situations very carefully. He is excellent."

Department profile by BCL Solicitors LLP

Department profile not yet provided by BCL Solicitors LLP. Please see their firm profile.

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Byrne and Partners LLP - POCA Work & Asset Forfeiture

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Band 1

第一等

Commentary from the Chambers UK guide

Basic facts about the department
- 5 partners
- 5 other qualified lawyers
- Office location: London

What the team is known for Noted capabilities handling regulatory compliance, pre-charge restraint orders, criminal and civil forfeiture as well as post-conviction confiscation proceedings. Regularly acts for defendants, third parties and court receivers. Experienced in cross-border matters, including mutual legal assistance requests and jurisdictional challenges.

Strengths Sources say: "The firm has an unrivalled ability to deal with cross-border POCA cases and the criminal/civil crossover. They understand the danger of being proceeded against by the criminal authorities of more than one country. They have strong understanding of the civil POCA regime."

Commentators say: "Byrne and Partners is a genuinely top-tier firm who have acted in many of the big law-making POCA and asset-related cases."

Work highlights Represented Blue Holding in civil asset forfeiture proceedings brought by the National Crime Agency in relation to assets said to be the proceeds of fraud and corruption during the Abacha era in Nigeria.

Notable practitioners

Matthew Frankland has extensive experience in the defence of major criminal fraud cases in addition to restraint, confiscation and asset forfeiture proceedings. Sources say: "Matthew Frankland stands out as a defence solicitor who genuinely considers the POCA and asset recovery implications of a case from the outset, a stage at which such things are often far from the client's mind. He is outstanding."

Michael Potts advises on all aspects of POCA and asset forfeiture, both domestically and cross-border. Market commentators describe him as "a well-rounded lawyer" who is "sensible and pragmatic."

Department profile by Byrne and Partners LLP

Department profile not yet provided by Byrne and Partners LLP. Please see their firm profile.

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Cartwright King - POCA Work & Asset Forfeiture

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Band 1

第一等

Commentary from the Chambers UK guide

Basic facts about the department
- 10 partners
- 22 other qualified lawyers
- Office locations: Nottingham, London, Manchester

What the team is known for Well-respected firm representing defendants and third parties in restraint, confiscation, cash seizure and enforcement matters. Has a strong regional network and noted experience handling specialised regulatory POCA cases. Advises on POCA proceedings arising out of both general and financial crime, including high-value fraud and money laundering cases.

Notable practitioners

Richard Cornthwaite has significant experience in POCA and asset forfeiture, including restraint, confiscation and cross-border asset recovery measures.

Mark Fowler is particularly recognised for his expertise in carousel VAT frauds. Sources say: "Mark Fowler has great relations with clients and an excellent grasp of the issues involved in complex cases."

Mark Hopwell is regional managing director for the firm's Northern operations. He is experienced handling restraint and confiscation proceedings.

Department profile by Cartwright King

Department profile not yet provided by Cartwright King. Please see their firm profile.

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Kingsley Napley LLP - POCA Work & Asset Forfeiture

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Band 1

第一等

Commentary from the Chambers UK guide

Basic facts about the department
- 15 partners
- 28 other qualified lawyers
- Office location: London

What the team is known for Outstanding practice which frequently defends corporate entities and high-profile individuals in restraint and money laundering matters. Also acts for public bodies in confiscation proceedings. Regularly advises on compliance issues relating to criminal and regulatory liability under POCA. Continues to be instructed on complex, high-profile and cross-border cases.

Strengths A source says: "I like using Kingsley Napley because of their depth of understanding of criminal and regulatory matters, and their general strength in depth. They are an excellent firm to have working alongside you."

Commentators add: "They are clear and direct in their advice, with very good client skills. They reassure their clients and are responsive."

Notable practitioners

Jonathan Grimes is experienced advising on POCA proceedings arising out of fraud and money laundering cases. He acts for individuals subject to restraint and confiscation orders as well as third parties to proceedings. Commentators report: "Jonathan is a diligent and careful lawyer."

Department profile by Kingsley Napley LLP

Department profile not yet provided by Kingsley Napley LLP. Please see their firm profile.

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Peters & Peters Solicitors LLP - POCA Work & Asset Forfeiture

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Band 1

第一等

Commentary from the Chambers UK guide

Basic facts about the department
- 8 partners
- 11 other qualified lawyers
- Office location: London

What the team is known for Respected financial crime practice regularly advising high-profile individuals on POCA issues arising from investigations and prosecutions. Also offers advice on restraint, with particular experience advising affected third parties. Popular choice for clients involved in high-profile, high-value and cross-border proceedings.

Strengths Commentators say: "Their strengths are their dedication and willingness to do everything possible to look after their clients' interests. They are conscientious and meticulous in the preparation that they put into all their work."

Work highlights Represented the beneficial owner of funds subject to a large-scale cash seizure. The British Virgin Islands-registered firm is alleged to have been involved in laundering the proceeds of a Ponzi scheme.

Acted for Khadem Al Qubaisi and companies connected with him on a major civil forfeiture case brought by the US DOJ, in the context of fraud, corruption and money laundering proceedings brought in multiple jurisdictions.

Notable practitioners

Michael O’Kane is a key contact.

Department profile by Peters & Peters Solicitors LLP

A restraint order can be made against a suspect or defendant in criminal proceedings to freeze assets worldwide where the authorities believe they may be liable to confiscation following a trial. Confiscation proceedings are brought following a conviction and enable the authorities to deprive the defendant of the financial benefit of his crime. In some circumstances, Restraint & Confiscation orders can also be made against third parties.

We have extensive experience in advising clients and third parties affected by such proceedings, often leading to variation or discharge of any prohibiting orders. We have successfully challenged a number of restraint orders made at the request of overseas authorities.

The Proceeds of Crime Act 2002 enables the police or customs to seize cash of more than £1,000 if they believe that the cash is the proceeds of crime or intended for use in unlawful conduct. Peters & Peters can help challenge cash seizures and/or consequent forfeiture proceedings, often resulting in money being returned and the recovery of costs.

Our lawyers specialise in:

  • Acting in pre-charge and post-charge restraint proceedings
  • Dealing with post-conviction confiscation proceedings
  • Advising third parties faced with the exercise of compulsory powers under proceeds of crime legislation
  • Acting in Magistrates’ Court cash seizure proceedings
  • Cash Seizure & Forfeiture

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Blackfords LLP - POCA Work & Asset Forfeiture

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Band 2

第二等

Commentary from the Chambers UK guide

Basic facts about the department
- 2 partners
- 33 other qualified lawyers
- Office location: London

What the team is known for Respected firm with a strong reputation for handling high-profile fraud, POCA and asset forfeiture matters. Offers a specialist confiscation and restraint team which handles complex proceeds of crime work. Frequently instructed in POCA proceedings arising from high-profile criminal frauds, drug supply cases and robberies.

Strengths Sources comment: "The POCA team at Blackfords are a class act. They are always conscious of and alive to the consequences for POCA when considering the advice given in the original proceedings, meaning that many of the key issues for confiscation have already been resolved in their client's favour before the Crown even begin to think about that stage of the investigation."

Commentators say: "They conduct complicated and high-profile work, taking on difficult confiscation cases after trial."

Work highlights Acted for John Collins, the lead defendant in the 2015 Hatton Garden burglary, in relation multimillion-pound POCA proceedings following his entering of a guilty plea.

Notable practitioners

Solicitor advocate Nadia Ryman is praised for her "specialist knowledge" of POCA legislation. She is particularly focused on confiscation matters and represents clients in the UK and abroad. Market commentators say: "Nadia is a committed lawyer who shows dedication to her clients. She understands this area of law and works hard to ensure her clients get the best possible results."

Gary Bloxsome is described as a remarkable team leader by sources, who report: "He is always there to make sure things are running smoothly. He has a real grasp of all the cases being dealt with by his firm, and is always present if there is an issue." He is experienced advising on confiscation and restraint orders in the context of serious crime, fraud and money laundering.

Sarah Hall is a solicitor advocate for whom "nothing is too much effort." She has a strong and growing reputation for restraint, confiscation and seizure work. She is praised by sources as "industrious, dedicated and creative in solving what appear to be daunting issues."

Department profile by Blackfords LLP

Department profile not yet provided by Blackfords LLP. Please see their firm profile.

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Corker Binning - POCA Work & Asset Forfeiture

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Band 2

第二等

Commentary from the Chambers UK guide

Basic facts about the department
- 6 partners
- 10 other qualified lawyers
- Office location: London

What the team is known for Boutique practice advising individuals and corporates on white-collar and business crime, as well as related proceeds of crime cases. Experienced in cross-jurisdictional confiscation matters, cash seizures and restraint orders. Able to offer a comprehensive service to clients thanks to top-tier crime, extradition and financial crime practices. Accepts both legal aid and privately funded cases.

Strengths Sources say: "They are realistic and have their clients' best interests at heart. They are very committed to the work they do and also rigorous."

Commentators say: "They know what they are talking about, they have good ideas and they take the lead."

Notable practitioners

Andrew Smith advises clients on POCA proceedings arising out of fraud, corruption and money laundering cases. Market commentators say: "He has a wisdom beyond his years. He is very thoughtful. He acts on high-profile cases and keeps his cool in any situation."

Jessica Parker has significant experience acting for individuals in POCA proceedings arising from bribery and money laundering cases. One source reports: "Jessica Parker is an acute tactical thinker who always keeps the interests and sensitivities of her clients at the forefront of her mind."

Department profile by Corker Binning

Corker Binning is a niche practice which largely focusses on white collar crime. As such, the majority of the firm’s cases include an element of unlawful financial gain (the proceeds of crime). The firm has substantial experience of advising companies and individuals on confiscation proceedings, cash seizures and restraint orders and is the first port of call for many clients facing POCA proceedings.

The firm act in some of the largest and most complex international confiscation and cash forfeiture cases. Recent cases involved Dubai, Algeria, Switzerland and Italy.

Corker Binning takes a strategic approach to the confiscation regime, from the beginning of an investigation to post conviction confiscation. The team will seek to negotiate with the prosecuting authority to avoid the restrictions of a Restraint Order; negotiate with the prosecuting authority to ensure that conviction orders are agreed as a package with their plea to avoid lengthy, costly and uncertain confiscation proceedings. The team’s experience and tenacity enables them to negotiate fair and favourable outcomes for all clients.

Partners Jessica Parker and Peter Binning also provide free advice to fellow solicitors via the Law Society’s Anti-Money Laundering Guidance Scheme.

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Kangs Solicitors - POCA Work & Asset Forfeiture

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Band 2

第二等

Commentary from the Chambers UK guide

Basic facts about the department
- 1 partners
- 14 other qualified lawyers
- Office locations: London, Birmingham, Manchester

What the team is known for Dedicated white-collar crime team handling confiscations, restraint orders and cash seizures. Frequently represents high-profile individuals in proceeds of crime proceedings following convictions for fraud, money laundering and conspiracy to supply drugs.

Strengths Sources say: "The firm is well managed and has a number of lawyers who are true experts in the areas of confiscation and asset forfeiture. Kangs is one of a handful of firms which operate on a national level and repeatedly secure multimillion-pound instructions in relation to confiscation and asset forfeiture work."

Market commentators add: "Kangs is a very proactive firm. They are always very quick off the mark in cases, which provides clients with great reassurance. They are always available to meet with clients at short notice, which is invaluable as often the advice being sought is urgent."

Notable practitioners

Hamraj Kang is an expert in fraud and serious criminal cases. He receives high praise from market commentators, with one saying: "He is a very experienced and dedicated lawyer who has worked on many of the largest confiscation cases in the country in recent years. He has a natural rapport with clients. He has the ability to provide clients with a clear road map in even the most difficult cases. A great lawyer and a great team leader – you would want him on your side."

Frances Murray advises on POCA proceedings arising from fraud and drug supply cases. Sources describe her as "very detailed, methodical and client-friendly."

Department profile by Kangs Solicitors

Department profile not yet provided by Kangs Solicitors. Please see their firm profile.

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Rahman Ravelli Solicitors - POCA Work & Asset Forfeiture

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Band 2

第二等

Commentary from the Chambers UK guide

Basic facts about the department
- 1 partner
- 14 other qualified lawyers
- Office locations: London, Birmingham, Halifax

What the team is known for Recognised as one of the leading firms for civil recovery cases, with broad expertise and experience defending clients in proceedings initiated by the National Crime Agency. Also adept at handling high-value confiscation cases, including instructions received post-conviction. Regularly handles proceedings arising from drug supply, mortgage fraud, money laundering and tax evasion cases.

Strengths Commentators say: "Its main strengths are that the firm has in its staff a huge wealth of experience and talent; no case is too small or too big. The firm seems to be able to take on the most complicated cases in its stride."

Sources comment: "Rahman Ravelli have a superb team and can take on the NCA in all aspects of POCA cases."

Notable practitioners

Aziz Rahman regularly represents individuals in POCA proceedings arising from fraud and drug supply cases. Sources are impressed by his knowledge, saying: "He is incredibly focused and driven. He knows the POCA landscape inside out. He has a very realistic attitude towards what you can achieve and he is also very good at strategising."

Department profile by Rahman Ravelli Solicitors

POCA AND ASSET FORFEITURE

Rahman Ravelli's innovative ways of challenging the authorities and identifying weaknesses in allegations have seen it officially recognised as one of the best firms for defending people's assets.

Each member of the firm's top-ranked asset forfeiture team is vastly experienced in this field, can boast huge amounts of expertise and possesses a desire and commitment to achieve the very best result for every client.

This is why Rahman Ravelli has come to be viewed as the market leader in this area of law. Its long and impressive record of success and its unique reputation for taking cases to the highest possible courts, including the European Court of Human Rights, have made it the stand-out firm in this field.

The almost draconian provisions of the Proceeds of Crime Act 2002 can leave people feeling shocked when they are the subject of forfeiture proceedings. Rahman Ravelli's skill in developing the strongest defence strategy at the earliest opportunity gives clients the best possible chance of keeping what is theirs.

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Hickman & Rose - POCA Work & Asset Forfeiture

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Band 3

第三等

Commentary from the Chambers UK guide

Basic facts about the department
- 5 partners
- 3 other qualified lawyers
- Office location: London

What the team is known for Represents clients in confiscation proceedings arising from serious fraud convictions. Advises both companies and individuals on compliance with POCA and potential liabilities in civil and criminal law. Also advises victims of crime on recovery measures.

Work highlights Advised an investment company on its POCA reporting obligations and potential liability in relation to money laundering allegations after it discovered that a construction company it was funding was involved in bribery, theft and asset stripping.

Advised a senior banker on a UK freezing order placed over her assets after she was accused of soliciting bribes.

Notable practitioners

Andrew Katzen specialises in asset recovery, money laundering and confiscation matters. He has experience advising third parties to POCA proceedings as well as victims of crime seeking recovery of assets.

Department profile by Hickman & Rose

Our Proceeds of Crime Act (POCA) team has a well-established practice and defends in both criminal and civil asset recovery and forfeiture. We are often instructed as a POCA specialist after conviction where other firms have handled a criminal trial. Though most of the firm’s POCA cases involve advisory and civil recovery work for private clients, the general crime team sees confiscation as a driving force behind many prosecutions, and in dishonesty cases a claim is inevitable.
The team has been successful in many cases in repelling the efforts of both government agencies and Non-Departmental Public Bodies to employ the civil provisions of POCA to achieve their policy ends eg, our successful defence of a client against a POCA forfeiture attempt made by the Medicines and Healthcare products Regulatory Agency.
We have also seen an increasing demand in recent years for POCA recovery advice from corporate and individual clients who are the victims of crime.
Many cases have an international element, and there is increasingly a focus on the hazards of double recovery across jurisdictions. We are accustomed to dealing with regulators in the US, the EU and the UK seeking to impose civil penalties resulting from the same set of facts.
We also advise regularly on compliance issues. One of the team’s senior partners, Ross Dixon, is on the Law Society Money Laundering task force, and we are the firm of choice for many other solicitors with AML concerns.

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Shearman Bowen & Co - POCA Work & Asset Forfeiture

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Band 3

第三等

Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 6 other qualified lawyers
- Office location: London

What the team is known for Boutique crime and POCA practice handling confiscation and restraint orders. Advises on recovery proceedings arising out of fraud, corruption and money laundering cases.

Strengths Sources say: "The strength of the firm lies in the quality and depth of the representation on offer, and the ability of the solicitors to generate superb written work and present complex evidence in a manner that Crown Court judges can readily interpret."

Work highlights Represented the lead defendant in a high-value boiler-room fraud case and in complex confiscation proceedings.

Notable practitioners

Mark Bowen has extensive experience in handling confiscation cases arising out of serious criminal convictions. Interviewees praise him for his "empathy, respect, determination, negotiation skills, strategy, knowledge and intelligence."

Colette Kelly handles confiscation cases involving offshore and cross-border elements. Sources say: "She is incredibly hard-working and industrious, she would do anything for a client. She gives them undivided attention. She explains the law very well to clients who have never been involved in these types of cases."

Department profile by Shearman Bowen & Co

Department profile not yet provided by Shearman Bowen & Co. Please see their firm profile.

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Band 1

Matthew Frankland

Byrne and Partners LLP

From the Chambers UK guide

Matthew Frankland has extensive experience in the defence of major criminal fraud cases in addition to restraint, confiscation and asset forfeiture proceedings. Sources say: "Matthew Frankland stands out as a defence solicitor who genuinely considers the POCA and asset recovery implications of a case from the outset, a stage at which such things are often far from the client's mind. He is outstanding."

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Band 1

Kingsley Napley LLP

From the Chambers UK guide

Jonathan Grimes is experienced advising on POCA proceedings arising out of fraud and money laundering cases. He acts for individuals subject to restraint and confiscation orders as well as third parties to proceedings. Commentators report: "Jonathan is a diligent and careful lawyer."

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Band 1

Rahman Ravelli Solicitors

From the Chambers UK guide

Aziz Rahman regularly represents individuals in POCA proceedings arising from fraud and drug supply cases. Sources are impressed by his knowledge, saying: "He is incredibly focused and driven. He knows the POCA landscape inside out. He has a very realistic attitude towards what you can achieve and he is also very good at strategising."

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Band 1

Richard Sallybanks

BCL Solicitors LLP

From the Chambers UK guide

Richard Sallybanks is widely recognised as an expert in POCA work. Commentators say: "He is extremely user-friendly, brilliant at running the show and keeping everybody informed and happy." He is experienced handling domestic and international investigations with restraint, confiscation and money laundering aspects.

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Band 2

Blackfords LLP

From the Chambers UK guide

Gary Bloxsome is described as a remarkable team leader by sources, who report: "He is always there to make sure things are running smoothly. He has a real grasp of all the cases being dealt with by his firm, and is always present if there is an issue." He is experienced advising on confiscation and restraint orders in the context of serious crime, fraud and money laundering.

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Band 2

Shearman Bowen & Co

From the Chambers UK guide

Mark Bowen has extensive experience in handling confiscation cases arising out of serious criminal convictions. Interviewees praise him for his "empathy, respect, determination, negotiation skills, strategy, knowledge and intelligence."

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Band 2

Richard Cornthwaite

Cartwright King

From the Chambers UK guide

Richard Cornthwaite has significant experience in POCA and asset forfeiture, including restraint, confiscation and cross-border asset recovery measures.

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Band 2

Kangs Solicitors

From the Chambers UK guide

Hamraj Kang is an expert in fraud and serious criminal cases. He receives high praise from market commentators, with one saying: "He is a very experienced and dedicated lawyer who has worked on many of the largest confiscation cases in the country in recent years. He has a natural rapport with clients. He has the ability to provide clients with a clear road map in even the most difficult cases. A great lawyer and a great team leader – you would want him on your side."

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Band 2

Hickman & Rose

From the Chambers UK guide

Andrew Katzen specialises in asset recovery, money laundering and confiscation matters. He has experience advising third parties to POCA proceedings as well as victims of crime seeking recovery of assets.

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Band 2

Byrne and Partners LLP

From the Chambers UK guide

Michael Potts advises on all aspects of POCA and asset forfeiture, both domestically and cross-border. Market commentators describe him as "a well-rounded lawyer" who is "sensible and pragmatic."

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Band 2

Blackfords LLP

From the Chambers UK guide

Solicitor advocate Nadia Ryman is praised for her "specialist knowledge" of POCA legislation. She is particularly focused on confiscation matters and represents clients in the UK and abroad. Market commentators say: "Nadia is a committed lawyer who shows dedication to her clients. She understands this area of law and works hard to ensure her clients get the best possible results."

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Band 3

Cartwright King

From the Chambers UK guide

Mark Fowler is particularly recognised for his expertise in carousel VAT frauds. Sources say: "Mark Fowler has great relations with clients and an excellent grasp of the issues involved in complex cases."

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Band 3

Cartwright King

From the Chambers UK guide

Mark Hopwell is regional managing director for the firm's Northern operations. He is experienced handling restraint and confiscation proceedings.

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Band 3

Corker Binning

From the Chambers UK guide

Jessica Parker has significant experience acting for individuals in POCA proceedings arising from bribery and money laundering cases. One source reports: "Jessica Parker is an acute tactical thinker who always keeps the interests and sensitivities of her clients at the forefront of her mind."

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Band 3

Corker Binning

From the Chambers UK guide

Andrew Smith advises clients on POCA proceedings arising out of fraud, corruption and money laundering cases. Market commentators say: "He has a wisdom beyond his years. He is very thoughtful. He acts on high-profile cases and keeps his cool in any situation."

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Up and Coming

BCL Solicitors LLP

From the Chambers UK guide

Shaul Brazil is a well-regarded POCA practitioner, focusing on corporate crimes and regulatory enforcement. He has experience in cross-border restraint and confiscation measures. Sources report: "He is very clever, tenacious and hard-working. He analyses situations very carefully. He is excellent."

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Up and Coming

Blackfords LLP

From the Chambers UK guide

Sarah Hall is a solicitor advocate for whom "nothing is too much effort." She has a strong and growing reputation for restraint, confiscation and seizure work. She is praised by sources as "industrious, dedicated and creative in solving what appear to be daunting issues."

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Up and Coming

Stokoe Partnership Solicitors

From the Chambers UK guide

Amjid Jabbar of Stokoe Partnership represents clients in confiscation and asset recovery proceedings following fraud, drug importation and burglary convictions. One source comments: "He is incredibly bright and he instinctively knows what works. He is very good at avoiding prosecution and making sensible deals for his clients. But he is also very good at going to litigation. He is extremely able."

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Up and Coming

Shearman Bowen & Co

From the Chambers UK guide

Colette Kelly handles confiscation cases involving offshore and cross-border elements. Sources say: "She is incredibly hard-working and industrious, she would do anything for a client. She gives them undivided attention. She explains the law very well to clients who have never been involved in these types of cases."

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Star Associate

Blake Morgan

From the Chambers UK guide

Lucy Edwards of Blake Morgan is described as "personable, practical, responsive and flexible" by sources. She specialises in representing insolvency practitioners appointed as enforcement receivers under POCA.

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Star Associate

Cohen Cramer

From the Chambers UK guide

Helen Lynch of Cohen Cramer is praised for "her attention to detail and her first-rate negotiation skills." She has particular experience in confiscation proceedings. Commentators say: "She is very personable, outgoing and down-to-earth. Clients like her a lot. She is very direct and engaging."

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Associates to watch

Kangs Solicitors

From the Chambers UK guide

Frances Murray advises on POCA proceedings arising from fraud and drug supply cases. Sources describe her as "very detailed, methodical and client-friendly."

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