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UK Guide

Financial Crime: Individuals — London (Firms)

Overview

FINANCIAL CRIME: Individuals

Following last year’s varied outcomes in the LIBOR prosecutions, six traders now await trials in January 2018 in relation to allegations that they tried to manipulate EURIBOR. It will be interesting to see whether the SFO can improve on its success rate against a backdrop of confusion and criticism as to how to prove dishonesty in circumstances where the rules in place at the time permitted the conduct that is subsequently alleged to be a conspiracy to defraud.

In June 2017, the SFO charged Barclays plc in relation to emergency cash calls at the height of the financial crisis in 2008, and the bank’s advisory services agreement with Qatar. Furthermore, four individuals formerly with Barclays face various counts of fraud by false representation and conspiracy to commit fraud in relation to Barclays’ capital raising in 2008, with a criminal trial set for January 2019. One of the individuals was the former global bank CEO of Barclays in 2008, and the prosecution sees the first global chief executive of a bank to face criminal charges arising from the financial crisis. If the SFO are successful, this could be the start of a chain of further prosecutions arising from the 2008 financial crisis.

The past year saw the conclusion of Operation Tabernula, the FCA’s largest and most complex insider dealing investigation. The proceedings resulted in three acquittals and two convictions, with custodial sentences of three and a half and four and a half years in prison respectively, the latter being the longest custodial sentence for insider dealing in a case prosecuted by the FCA. The FCA’s focus on insider dealing continues to grow. In June 2017, two former UBS compliance officers were charged with insider dealing offences for passing on information between 2013 and 2014. This is a result of the FCA’s push to exercise its criminal powers more in the past year; the number of insider-dealing cases that the FCA is currently dealing with is over 70.

Following the successful conclusion of three deferred prosecution agreements (“DPAs”) in the past year – XYZ in July 2016, Rolls-Royce plc in January 2017, and Tesco Stores Ltd in April 2017 – the investigations and prosecutions of implicated individuals is now anticipated with interest. Widespread concerns having been expressed about potential unfairness; and without commenting on any one in particular, the pragmatic nature of the DPA route means that it might have been entered into for ‘commercial’ reasons and likely without regard for the implications on individuals in any subsequent prosecutions. Further, DPAs involve the organisation’s acceptance of a statement of facts, which may include admissions; and organisations seeking a DPA may find an advantage in dismissing former management and directing the blame at them. Former employees would not be party to and would have no visibility of the DPA proceedings. Further, they would have no right to make representations in respect of maintaining their anonymity. Importantly, the need for co-operation is likely to involve the organisation disclosing records of internal interviews, irrespective of legal privilege. While such an approach is helpful to an organisation intent on quick resolution and avoiding the risk of criminal conviction, the employees will rightly be concerned that such interviews were effectively under compulsion, if they were still employed at the time (and wished to remain in employment); and in any event are likely to have been undertaken in the absence of a formal caution. The widespread publicity surrounding the DPAs will only have increased the risk of unfairness and it will be interesting to see how the issues of fairness and admissibility are resolved at the forthcoming trials.

There has been one development in financial crime which will give individuals and organisations alike some cheer: the practice of law enforcement encouraging banks to end customer relationships by reducing account balances to a cheque or banker’s draft, which may be seized and ultimately forfeited pursuant to ‘cash’ seizure powers, has been declared unlawful by the High Court in Merida Oil Traders Ltd. Such action enabled officers to seize funds from bank accounts sometimes in the tens of millions of pounds, with nothing more than an officer’s belief that there were reasonable grounds to suspect that it derived from or was to be used in unlawful conduct. And while a magistrates’ court had to sanction the continued detention of cash within 48 hours, unless the subject of the seizure is in a position to oppose it, this was usually a formality.

The ‘innovation’ by law enforcement was particularly ripe for abuse in the context of money laundering, a complex offence which can be committed with nothing more than ‘suspicion’ that a person is dealing with the proceeds of crime (and ultimately proof that the property is the proceeds of crime). In the context of banking relationships, any number of factors might give rise to ‘suspicions’, including unusual or unexplained transactions or activity on the account and any enquiry by the police, whether reasonable or not, and whether directly into the customer or merely in respect of a person with whom they have dealt. The upshot was that individuals or businesses who crossed law enforcement’s radar, whether following the filing of a suspicious activity report by the bank or otherwise, risked having the entire contents of their bank accounts seized on a ‘hunch’. Following Merida Oil, and as was intended by Parliament, law enforcement will have to conduct a substantive criminal investigation; and if they want to prevent the money from being dissipated in the meantime, they will have to apply to the Court for a restraint or freezing order, where expert judicial scrutiny can be applied.

However, such is the current climate, Parliament is now rowing back on these protections. When the Criminal Finances Act comes into force, law enforcement officers with reasonable grounds for suspecting that £1,000 or more held in a bank or building society account represents the proceeds of crime, or is intended for use in crime, will be able to apply to a magistrates’ court for a freezing order in relation to the account (without notice in certain circumstances) and, within two years, for the money held in the frozen account to be forfeited. Crucially, there is no provision for a maximum amount. As the government and courts have repeatedly stated, in complex matters there should be a high level of scrutiny by a judge with an appropriate degree of expertise who will be able to balance the public interest of the impact on crime with the rights of those who may be affected. That is unlikely to be found via summary justice in the magistrates’ courts.

FINANCIAL CRIME: An Introduction to UK-wide Contributed by Richard Sallybanks, BCL Solicitors LLP
FINANCIAL CRIME: Cartel Investigations (July 2017)

Previous overviews have commented on a lack of enforcement activity in relation to the cartel offence in section 188 of the Enterprise Act 2002 and this trend continues in relation to criminal enforcement under both the original section 188 offence requiring dishonesty and under the (not so) “new offence”, amended by section 47 of the Enterprise and Regulatory Reform Act 2013 (in force from 1 April 2014 and not retrospective), which no longer requires the Competition and Markets Authority (“CMA”) to prove dishonesty.

The CMA’s website contains details of only one ongoing criminal case. This is in relation to the supply of precast concrete drainage products, an investigation which opened on 12 March 2013 and, as such, an investigation under the original section 188 offence. On 21 March 2016 one individual pleaded guilty and (at the time of writing) still awaits sentencing. Notwithstanding that guilty plea, the investigation continued into other suspects, but on 13 June 2017 the CMA announced that there was insufficient evidence to prosecute any other individuals in this investigation, and so the last remaining criminal case being investigated by the CMA under the old offence is almost at an end.

According to the CMA’s website, there are no live criminal cartel investigations under the “new offence”. Given that there was an anticipated upturn in the number of criminal cartel investigations, prosecutions and, ultimately, convictions following the introduction of the “new offence” and the removal of the requirement to prove dishonesty, the absence of any investigations in the three years since the new offence came into force (at least in the public domain) does not reflect well on the CMA.

Over fourteen years after section 188 came into force (June 2003), the CMA has had three successful prosecutions. The first was the “Marine Hose” case in 2008 (prosecuted by the CMA’s predecessor, the Office of Fair Trading) in which three British businessmen pleaded guilty to the section 188 offence as part of an agreement with the Antitrust Division of the US Department of Justice (having also entered guilty pleas in the US where they had been arrested) which enabled them to return to England to serve their prison sentences here. The second was the galvanised steel tank prosecution in 2015 which resulted in one defendant pleading guilty and assisting the CMA as a cooperating witness (two other defendants being acquitted at trial), and the third is the prosecution of a defendant in the case involving the supply of precast concrete drainage products referred to above.

The CMA’s Annual Plan 2017/18 published in March 2017 states in respect of their criminal investigations: “Our approach to the criminal cartel offence is guided by lessons learned from the galvanised steel tanks trial in 2015, where those defendants who were found ‘not guilty’ based their defence solely on the grounds that they had not acted ‘dishonestly’, and also on the fact that the law has now been changed so that, for conduct from April 2014 onwards, there is no longer a requirement for the CMA to prove that individuals acted dishonestly to establish the offence. We take a pragmatic view about launching criminal cases where the activity occurred before April 2014. Although they are, all other things being equal, more difficult to prosecute, we note that in the past two years, in two different cases, individuals have pleaded guilty in respect of pre-April 2014 activity. We are actively considering the launch of other cases involving cartel activity from April 2014 onwards, on the basis of ongoing intelligence work.”

However, the CMA’s criminal enforcement work features less prominently than their competition and consumer work in the Annual Plan which perhaps reflects their pragmatism. They do nevertheless say that a key commitment is to “open new criminal investigations and pursue prosecutions as appropriate, having regard to lessons from our most recent cases as well as the change in the law in respect of cartel activity occurring from April 2014.” It remains to be seen if their ongoing intelligence work bears fruit over the coming year but the fact remains that, since January 2014, no new criminal cartel investigations have been opened – does this suggest that no businesses are involved in cartel activity (which the CMA would say was not the case) or rather that the CMA appear to lack intelligence leads or investigative capabilities in this area?

Although not part of the CMA’s criminal enforcement work, a feather in the cap for the CMA last year was the disqualification of the Managing Director of Trod Ltd, a party to a price collusion cartel, for which they had issued an infringement decision in August 2016. The Managing Director was disqualified from acting as a director for five years in November 2016, “reflecting the fact that he had personally contributed to the breach of competition law.” These powers have been available to the CMA since 2003, but were used for the first time in this case.

In relation to prosecutions, one key issue for the CMA is how they make use of immunised witnesses and assisting/cooperating offenders as part of their leniency programme in criminal cartel investigations and prosecutions. The fact that a company and/or individuals can receive immunity from sanction and prosecution provided they meet certain conditions, including informing the CMA of the conduct before it has knowledge, admitting participation in the cartel conduct, and providing complete cooperation, can be attractive and encourages whistleblowing. However, the CMA readily acknowledge (see speech by Stephen Blake, Senior Director - Cartels and Criminal Group on 13 November 2015) that the immunity/cooperation process can be a double-edged sword as juries are prone to distrust the motives of immunised/cooperating witnesses who will have either avoided prosecution entirely or are hoping to secure a more lenient sentence. This may have been a factor in the acquittal of the galvanised steel defendants. However, the CMA will continue to use the leniency programme as they say it plays an important role in the investigation of cartels, but they will certainly have to consider very carefully how any immunised/cooperating witness is used in future prosecutions.

Despite the lack of live investigations, the fact remains that the removal of the dishonesty element does make it easier for the authorities to establish the criminal cartel offence. The CMA will no doubt be looking to use its intelligence and enforcement capability in the years ahead to establish its credentials, both domestically and internationally, as a credible and effective enforcement agency. Employees and directors must therefore continue to take seriously the risk of investigation, prosecution and (as the sentencing comments in the galvanised steel case demonstrated) likely imprisonment, and any individual caught up in such an investigation, or company lawyer looking to arrange representation for individuals who may have a personal criminal exposure, would be well-advised to seek specialist criminal law advice from one of the firms featured in the following table.

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Bark & Co - Financial Crime: Individuals

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Commentary from the Chambers UK guide

What the team is known for A noted and broad criminal defence practice, acting on legally-aided and privately funded work. Experienced advising on alleged financial trading offences such as insider dealing as well as bribery. Notable experience acting on tax frauds prosecuted by HMRC.

Strengths Sources describe the firm as a "really impressive outfit" with a team that is "utterly dedicated and professional."

Interviewees say: "They have a real niche and attract great clients."

Work highlights Represented Noel Cryan, a former Tullett Prebon broker who was acquitted on charges of conspiring to manipulate Libor.

Notable practitioners

Giles Bark-Jones founded the firm and continues to serve as its principal. He maintains a strong financial crime practice, with a notable record of handling SFO investigations into alleged fraud, corruption and money laundering. One source says: "He is really go-getting – I loved working with him."

Department profile by Bark & Co

Bark&co is one of the UK’s most successful fraud and business crime firms. We handle a wide range of white-collar crime and fraud cases, including prosecutions and investigations brought by the SFO, the FCA, HMRC, the Special Compliance Office of the Inland Revenue, the CPS, SOCA and other prosecuting bodies.

We became a member of the Serious Fraud Panel at its inception and members of the team are accredited as supervisors of the most serious and complex cases. Acknowledged as a leader in the field, the firm acts in many major prosecutions brought by the SFO and other agencies. Expertise encompasses carousel, mortgage, investment, pension fund, telecoms and internet frauds, as well as corruption, theft, fraudulent trading by company directors, tax and VAT, and money-laundering.

Notable recent work includes successfully representing Noel Cryan in the SFO prosecution following the LIBOR scandal; acting for four individuals in the SFO investigation into the Rolls Royce bribery allegations; acting in R v Franklin & ors, described by prosecution counsel as the ‘biggest case ever’ involving carbon trading fraud; representing an individual in the ‘bio-fuel’ investment fraud, the first SFO prosecution alleging offences under the Bribery Act; appearing in R v Asil Nadir, the high-profile prosecution by the SFO involving allegations of theft from the Polly Peck International group; and acting in R v Adoboli, the US$2.3bn trading loss fraud at UBS.

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INTERNATIONAL The firm’s work frequently extends overseas with specialist teams deployed for cases with a multi-jurisdictional element. Its international credentials are demonstrated by its involvement in R v Marrache & Co, an alleged client account fraud, which is notable as Gibraltar’s largest fraud case to date.





BCL Solicitors LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 7 partners
- 14 other qualified lawyers

What the team is known for A premier outfit with an excellent reputation for its representation of individuals including company directors, officers and employees. Boutique firm offering a large team with extensive experience in handling SFO investigations. Frequently advises on complex commercial fraud, regulatory enforcement and money laundering cases. Also demonstrates a strong capability in handling cartel investigations.

Strengths Sources say: "There is no doubt at all to me that BCL is the top of the top. They have good lawyers and a very good culture – they look after the client."

One commentator says: "They are extraordinarily knowledgeable about procedures and have dealt with all the big prosecutors. They are collaborative and work extremely diligently – high-quality and pragmatic."

Work highlights Acted for John Scouler, the former Tesco director for food, in the SFO investigation into alleged accounting irregularities at the company.

Provided counsel to members of the Ahsani family on the SFO investigation into Unaoil's allegedly corrupt activity in Iraq.

Notable practitioners

Commentators describe Richard Sallybanks as "calm, experienced and highly able," with one source noting that "he is extremely thorough, his judgement is excellent and his client handling is superlative." He provides expert counsel to senior executives on a range of criminal fraud matters, including corruption, money laundering and accounting fraud.

Ian Burton is a deeply experienced white-collar practitioner whose recent work includes a number of international anti-corruption matters. Sources commend him as a "rainmaker extraordinaire" who "picks up clients of the highest level."

Harry Travers maintains a wide-ranging practice defending clients from allegations of corruption, as well as other financial crime charges. He wins acclaim from commentators as a "relentless litigator" with a "tremendous analytical mind" and "great client skills."

Michael Drury draws on his national security background to provide expert counsel to clients in extradition cases, as well as international financial crime more broadly. Sources describe him as "an intellectual heavyweight whose points run a coach and horses through the other side."

The "bright and enthusiastic" Shaul Brazil is noted by commentators for an "urbane, easy-going manner that makes individuals warm to him." He is a qualified barrister with a growing reputation for his work in financial crime, which includes a number of multi-jurisdictional, multi-agency investigations.

Jane Glass is a long-standing fraud practitioner with a wide range of experience in the defence of government investigations into individuals. Sources commend her "fantastic presence and intellect."

Department profile by BCL Solicitors LLP

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Bindmans LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 7 other qualified lawyers

What the team is known for Active legal aid practice concentrating on high-exposure fraud matters with a wealth of experience in jury trial work. Recent mandates from the banking sector bolster the growing private client base. Experienced across the full range of criminal fraud and regulatory investigations.

Strengths Interviewees note that "their cases are always brilliantly prepared," adding: "They will always be 100% behind the client, looking for the best results. They are kind and effective, a difficult combination to achieve."

Sources describe the firm as "really passionate and really dedicated."

Work highlights Acted for Terry Farr, winning an acquittal at trial on charges resulting from the high-profile SFO investigation into the alleged manipulation of Libor.

Represented Peter Lewis, a senior hospital manager accused of accepting bribes from a contractor to whom he had awarded an IT contract.

Notable practitioners

Katie Wheatley has a wide-ranging criminal practice and a growing reputation for her fraud work for clients from the financial services industry. Sources comment that she is "fantastic with clients," with one interviewee saying: "She is incredibly hard-working and thorough."

Martin Rackstraw is an experienced criminal solicitor with a notable record of advising clients involved in SFO investigations. Interviewees commend him as a "good legal analyst" and an "excellent lawyer who brings his legal skills right out to the forefront of what he is doing."

Department profile by Bindmans LLP

Bindmans is a leading firm in defending clients facing allegations of fraud, financial and business crime. We have extensive experience in this complex and challenging field. For every client we represent, we bring to bear our renowned forensic skills in analysing the prosecution case, and our fierce commitment to our clients’ interests and rights in presenting their defence.

As criminal law specialists we have honed our skills though decades of experience in representing clients facing the most challenging investigations. We defend in relation to investigations by the Serious Fraud Office and regulators such as the Financial Conduct Authority and specialist police and Crown Prosecution Service teams. We provide immediate advice and representation in connection with arrest, search and seizure as well as advising in connection with ongoing investigations and prosecutions.

We are criminal law specialists with human rights expertise. We combine our knowledge of this niche area of law with an understanding of the corporate context that allows us to represent clients effectively in a range of criminal matters including fraud, insider dealing and market offences, Bribery and Corruption and Money Laundering.

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Many of our cases have international aspects. We work closely, were necessary, with lawyers and experts in other jurisdictions. We have particular expertise in cases involving allegations of bribery and corruption abroad, and allegations of cross-border fraud.


Blackfords LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 33 other qualified lawyers

What the team is known for Acts on behalf of those accused of high-level financial crime. Accomplished in defending allegations of insider trading, tax fraud and misleading corporate statements. Strong record in handling carbon credit frauds and prosecutions initiated by HMRC.

Strengths One source says: "Blackfords is outstanding in the area of financial crime."

Interviewees comment that the firm "has expanded considerably and gone from strength to strength."

Work highlights Represented Harpreet Bhatti, one of the defendants in a £40 million mortgage fraud case related to the alleged inflation of property valuations in order to secure loans from Barclays Private Client customers.

Notable practitioners

Daniel Cundy is a respected financial crime practitioner with a particular strength in handling high-value HMRC investigations. Interviewees suggest that "his knowledge of the way financial markets and crime work is really quite exceptional," noting: "He is particularly good at pre-trial abuse and disclosure."

Market commentators describe Gary Bloxsome as a "strategic thinker" with a "big client base" in financial crime. He serves as head of the firm's criminal team and advises on a wide range of fraud charges, including those relating to vishing and carbon credit matters.

Trevor Francis is the managing partner of the firm and an experienced criminal lawyer. His financial crime practice spans from corruption to insider dealing prosecutions by bodies including the SFO, HMRC and the FCA.

Department profile by Blackfords LLP

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Brown Rudnick LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 5 other qualified lawyers

What the team is known for A popular choice to act on major matters including investigations into suspected rate manipulation, as well as bribery and corruption. Deep experience representing senior executives facing SFO proceedings. Noted for expertise in regulatory matters on both sides of the Atlantic.

Strengths Commentators describe the team as "extremely competent, experienced people doing highly efficient and thorough work."

One client says: "They obviously have a lot of experience and practice – that shows clearly from the way they perform. I have no hesitation in recommending them."

Work highlights Represented four employees of Rolls-Royce in relation to both SFO and internal investigations into alleged corruption in the obtaining of contracts.

Acted for a senior accounting executive at Tesco in relation to the SFO investigation into the company's accounting practices.

Notable practitioners

Tom Epps wins praise for his representation of senior executives involved in SFO investigations into fraud, corruption and other financial crimes. In the words of one source, he "stands out for his rigour, candour and ability to separate major and minor issues."

Sources describe Mark Beardsworth as "a strong communicator with great networking skills" who is "able to grasp highly complex matters very quickly." He displays extensive experience in defending directors facing allegations including rate-fixing and corruption.

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Byrne and Partners LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 10 other qualified lawyers

What the team is known for Provides highly tailored business crime representation to a range of organisations and senior professionals, mainly in the financial services sector. Offers extensive expertise in corruption proceedings and regulatory investigations. A reliable choice for company executives facing potentially criminal SFO and FCA action. Strong record of acting in multi-agency rate-fixing investigations.

Strengths Sources say: "They continue to be a very impressive firm – the combined disciplines with their well thought of civil department gives them a really strong presence in the market."

Clients say: "Byrne and Partners are an extremely professional and focused firm."

Work highlights Secured an acquittal at trial for Ben Anderson, a trader charged with insider dealing following the FCA's Operation Tabernula investigation.

Acted for FH Bertling and a group of its officers, who were alleged to have made corrupt payments to an employee of the Angolan state oil company.

Notable practitioners

Matthew Frankland is a seasoned white-collar lawyer with notable recent experience representing individuals involved in alleged rate-fixing. Sources describe him as "one of these quiet, unsung heroes of the white-collar crime area," noting that he "does very high-quality work and does it well." Others consider him "a real go-to guy who is very easy to work with whether you're with or against him."

The "superb" Michael Potts is held in high regard for his wide-ranging practice in financial crime, which includes representing individuals facing insider dealing and corruption charges. Sources say that he "gives clear advice – even on difficult conceptual matters that require careful thought to lay out, he always does it in a clear and well-structured way."

David Byrne has deep financial crime experience, with a strong track record of representing clients under investigation by bodies including the SFO and HMRC. According to commentators, "he is authoritative and bold, tenacious and inventive, and he stands firmly for his client."

Sara Teasdale has a strong record of advising individual clients from the financial services industry facing criminal investigation, as well as related regulatory proceedings. Clients recommend her as an "extremely talented and experienced lawyer who has a comprehensive understanding of the field in which she operates," adding that she has an "impressive ability to quickly understand a complicated situation and identify the relevant points and issues."

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Cartwright King - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 7 partners
- 19 other qualified lawyers

What the team is known for Frequently handles bribery, corruption and internet fraud cases. Well equipped to take on fraud cases and confiscation proceedings. Provides efficient and effective representation, including of individuals accused of benchmark rate manipulation. Recent work includes defending individuals involved in a number of major SFO anti-bribery and corruption investigations.

Notable practitioners

Market commentators describe Richard Cornthwaite as "vastly experienced and super well connected." He is a financial crime veteran with a wide-ranging practice that includes defending individuals charged with fraud, corruption and insider dealing.

Department profile by Cartwright King

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Corker Binning - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 6 partners
- 10 other qualified lawyers

What the team is known for A compact and highly reputed business crime practice. Advises individuals, including company executives, implicated in widely reported criminal and regulatory investigations. Displays an impressive range of experience in handling investigations at both national and international levels, including a number of recent prosecutions by the FCA.

Strengths Clients say this is "a serious firm focused on providing the best advice to clients and which is not afraid to confront the difficult issues," adding that it "moves quickly and with an unprecedented thoroughness."

One commentator describes Corker Binning as "a very strong firm in its field."

Work highlights Represented the former CEO of Tesco, Philip Clarke, in an SFO investigation into alleged accounting failures at the company that ended without charges being brought against him.

Acted for Nicholas Reynolds, a former executive of a subsidiary of the Alstom Group charged with corruption and conspiracy to corrupt in relation to payments allegedly made to win a construction contract in Lithuania.

Notable practitioners

Peter Binning wins widespread plaudits for his work defending individuals from high-profile fraud and corruption charges. One source reports: "In that particular field of representing senior corporate individuals, he is clever, has great judgement and is a really great tactician," adding that "he has that tactical nous as well as the bedside manner – it's a killer combination."

According to commentators, David Corker "has led some big shifts in thinking" in the field, maintaining his long-standing reputation as "a fantastic criminal defence lawyer used to operating in a corporate space." His top-drawer white-collar practice sees him act for individual clients under investigation by bodies including HMRC, the SFO and the FCA.

Andrew Smith draws on complementary expertise in extradition and confiscation to provide counsel to clients on criminal charges including money laundering and insider dealing. Commentators say that "he is very responsive and very energetic in the way he approaches a problem," as well as "a real pleasure to deal with."

Jessica Parker enjoys a growing reputation for her white-collar practice, which has recently included a particular focus on corruption. Sources report that "she is very cool and collected," as well as demonstrating "a model of very good client care, rolling up her sleeves and immersing herself in the case."

Department profile by Corker Binning

Corker Binning handles top level financial crime work of all types, including fraud, bribery and corruption, money laundering, extradition and mutual legal assistance, export controls, sanctions and international investigations, including investigations/prosecutions brought by the SFO, FCA and NCA (including joint investigations with foreign bodies).

The firm has an exceptional record and have acted in all of the SFO’s most significant investigations including Tesco, Libor, Euribor, FX, Barclays/Qatar, Rolls Royce, Unaoil, Tata Steel, Bank of England liquidity auctions, Glaxo Smith Kline, Alstom and G4S.

Corker Binning recently represented Philip Clarke, the former CEO of Tesco, in the high profile SFO investigation into his alleged role in the £263 million black hole discovered in Tesco’s accounts in 2014. No charges were brought against Mr Clarke.  

Corker Binning has a deservedly high reputation in financial crime work, having achieved this within a relatively short space of time due to the team’s considerable expertise in this area.

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Corker Binning act in some of the most complex and high-profile international investigations, including investigations/prosecutions brought by the SFO, FCA and NCA (including joint investigations with foreign bodies).


Hickman & Rose - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 4 other qualified lawyers

What the team is known for London-based corporate crime practice acting for individuals accused of various offences including bribery, revenue fraud and regulatory breaches. Regularly instructed by senior professionals from large corporations involved in major SFO and HMRC investigations. Noted for its increasingly high-profile and high-value work in the financial services industry, as well as its growing presence in cross-border investigations.

Strengths One client describes the firm as "very professional and sympathetic to my requirements."

Work highlights Defended Chris Bush, the former managing director of Tesco, from charges of fraud by abuse of position that arose from the SFO's investigation of the company's alleged £250 million overstatement of profits.

Acted for Ryan Reich, a former Barclays trader who was charged by the SFO for his alleged role in the manipulation of Libor. Won an acquittal at trial.

Notable practitioners

Ross Dixon wins recognition from interviewees as an "absolutely excellent" white-collar solicitor who is "low-key but very on the money." He offers a great deal of recent experience acting for individual clients under investigation by the SFO for alleged bribery and corruption offences.

Andrew Katzen maintains a well-regarded practice in the representation of clients under investigation for criminal fraud. Sources commend his "very sensible approach to his cases."

Ben Rose is an experienced practitioner in this space, with an impressive record of acting for clients accused of offences including bribery and market manipulation. He has recently handled a number of cross-border matters involving regulators in multiple jurisdictions.

Department profile by Hickman & Rose

The financial crime team are regularly instructed in complex financial crime cases involving private clients and have handled many of the major investigations of recent years into hedge funds, banks, insurance companies and individuals for insider dealing, market abuse and regulatory offences. Our lawyers advise strategically in cases at the interface between financial crime and financial services regulation. 

We have developed extensive expertise cross-border financial crime cases, much of it very complex. Among its areas of expertise are how to deal with US investigations in the UK, defending cross-border bribery and corruption matters and running or responding to internal investigations.
Our clients are served by a highly evolved team-working system and information-pooling structures, with expertise shared across professional boundaries, including both barristers and solicitors, with experience in banking, industry and FSA enforcement. Limiting or preventing reputational damage is extremey important, and we have an outstanding track record in pursuing successful complaints, challenges and compensation claims.

Current clients include major cases including the most senior of the Tesco defendants in the £250m revenue recognition case, a former senior finance executive of Autonomy, the company in the frame for Hewlett Packard’s woes. We also act for a number of LIBOR defendants, and have clients involved in the ENRC, Una Oil and Rolls Royce investigations by the SFO.

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Hodge Jones & Allen LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 5 partners
- 5 other qualified lawyers

What the team is known for Committed to handling legal aid-funded and privately funded matters in the financial crime space. Regularly instructed in high-level investigations led by the SFO, HMRC and the FCA. Recent mandates include advising on allegations of bribery and tax fraud. Also fields experience in handling money laundering prosecutions.

Strengths Interviewees commend this as a "really good, hard-working firm of solicitors."

Work highlights Represented Bradley Moore, who was charged with conspiracy to commit fraud in respect of his role in an alleged boiler-room fraud selling metal oxides to the public.

Defended Michael Moore, who was alleged by the FCA to have participated in fraudulent trading in a company's shares and to have misled investors as to the financial health of the company.

Notable practitioners

Kiran Mehta is a criminal solicitor with a growing reputation in fraud and financial crime. Interviewees say he is "very bright and definitely going places," with one source commenting: "He is very hard-working, brilliant at spotting issues and an amazing strategist."

Department profile by Hodge Jones & Allen LLP

Who we are:

The Financial Crime team is made up of a number of partners with considerable experience in complex and often high profile cases. Our leading team of solicitors understand the traumatic effect an investigation for fraud can have on you, your family and your business. At the heart of what we do, is a passionate determination to fight your corner every step of the way to secure the best possible outcome for you.

Our areas of expertise include:

  • Bribery and corruption

  • Carousel and MTIC fraud

  • Conspiracy to defraud

  • Health and safety/company investigations

  • Insider dealing

  • LIBOR

  • Money laundering

  • Regulatory and disciplinary investigations

  • Restraint, confiscation and cash seizure

  • Seizure and forfeiture of assets

  • Tax investigations

We combine a bespoke service tailored specifically to your needs, with technical abilities of the highest quality. Clients trust us and recommend us, which is why most of our instructions come from personal referrals. Some of our most notable cases include:

R v Revell-Reade & Others - We represented the 1st defendant in £100m ‘boiler-room’ fraud concerning the unregulated sales of US penny stocks from pink sheets & OTCBB to UK investors. 
R v Fisher & others - We were instructed in a £14m mortgage fraud case following Panorama investigation into corruption regarding a block of new flats in South East London. All defendants were acquitted following 10 week trial.

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Howard Kennedy LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 2 partners
- 3 other qualified lawyers

What the team is known for Expanding team with a notable record of representing individuals facing SFO investigations. Capable of handling the full range of fraud matters, with particular strength in anti-money laundering.

Strengths Sources say: "For representing individuals in financial crime or in the regulatory space, they are certainly highly regarded and excellent defence practitioners."

Notable practitioners

Ian Ryan is widely recognised as a "very experienced fraud and criminal lawyer with excellent judgement and tactical skills." His extensive financial crime practice includes a great deal of rate-fixing work. Sources describe him as a "really good tactician" who is "hard-working and very well respected."

Kevin Robinson has recently moved to Howard Kennedy from Morgan, Lewis & Bockius. His wide-ranging white-collar practice includes significant experience in handling criminal cartel matters. Sources commend his "immaculate judgement," adding that "his strategic approach both before charge and at trial is frankly unmatched."

Department profile by Howard Kennedy LLP

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Irwin Mitchell - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 2 partners
- 8 other qualified lawyers

What the team is known for A practice with long experience advising on white-collar criminal matters, such as alleged tax frauds and benchmark rate manipulation. Regularly sought after by individuals involved in high-profile investigations and prosecutions led by HMRC and the CPS. Significant record of acting on criminal insider dealing proceedings against the FCA.

Notable practitioners

The "clever and highly committed" Sarah Wallace wins recognition from interviewees for her "good client care skills." She is an experienced practitioner with a strong record of advising on matters at the intersection of financial crime and regulatory proceedings.

Department profile by Irwin Mitchell

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Janes Solicitors - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 3 partners
- 3 other qualified lawyers

What the team is known for High-quality niche practice which punches above its weight in terms of heavyweight financial crime instructions. Renowned for its command of substantial fraud and tax fraud matters. Draws mandates for the representation of individuals in many of the most high-profile prosecutions by agencies including HMRC and the SFO.

Strengths A client says: "I believe that the firm provided a service that was at the top of the scale – fast response time, industry knowledge at its best and strength and depth in its team."

Interviewees say this is "a dynamic law firm capable of handling both large and complex financial criminal cases. Cases are well managed, with staff showing an interest in the detail of the cases."

Work highlights Acted for Faisal Khan and other members of his family on a £40 million mortgage fraud, winning an acquittal at a retrial.

Notable practitioners

The "immensely experienced" David Janes is widely regarded as an "extremely astute tactician" with an impressive record in the full range of financial crime matters. Clients describe him as an "exceptionally clear thinker," with one source highlighting his ability to "find avenues that other lawyers seemed not even to be aware of."

Simon Barker represents individual clients facing a wide range of financial crime charges, with notable recent experience in tax and contract fraud, as well as market manipulation. Interviewees say: "He is extremely diligent and builds a great rapport with clients."

Department profile by Janes Solicitors

Janes Solicitors is a niche practice based in the heart of St James, London.

Our formidable team of lawyers offer extensive experience covering all areas of financial crime, bribery and corruption, serious and complex fraud, confiscation, freezing orders, civil recovery, regulation and taxation. We provide specialist advice from across our team.

Janes Solicitors are renowned for the exceptional result we achieve for our clients, our high-profile successes, combined breadth and depth of knowledge and the exceptional level of service we offer to clients. Our personal approach and fearless commitment gives us the edge over other firms meaning we are highly sought after by clients.

The firm handles an exceptional caseload including instructions in major Serious Fraud Office, HMRC and Trading Standards prosecutions. We act for clients globally including the United Arab Emirates, the Far East, the USA and South America.

Our lawyers are highly experienced in all aspects of financial crime including:

  • Serious Fraud Office Prosecutions
  • Mortgage Fraud
  • Tax Avoidance
  • Market Abuse
  • Section 2 Notices
  • NCA Prosecutions
  • Freezing Orders/Injunctions
  • Cyber/ Internet Fraud


If you have an enquiry which is covered by the above topics or any similar case or if you are unsure, contact us now and we will be happy to discuss this with you.

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We regularly represent clients from across the world including the USA, Middle East, Far East and Asia.  Janes Solicitors have extensive experience in handling cases involving multiple jurisdictions such as the British Virgin Islands, Mauritius, Cayman Islands, Switzerland, Liechtenstein, North and South America and across Europe.


Kingsley Napley LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 11 partners
- 18 other qualified lawyers

What the team is known for Renowned for its command of process and procedure across a broad array of criminal and regulatory work, including professional discipline as well as financial crime. Sought out to advise on the most high-profile investigations and criminal prosecutions of the day, including SFO, FCA and CMA matters. Fields a large team of well-regarded individual lawyers.

Strengths One source calls this "an absolute superfirm," saying: "They are the first firm I would think of when I represent a company and want an individual covered."

One client says: "I believe their strength lies in their meticulous attention to detail and the intelligence of the individuals employed by that firm. I could not imagine a better law firm."

Work highlights Secured an acquittal at trial for Darrell Read, one of the ICAP brokers charged with conspiring to manipulate Libor by procuring incorrect submissions.

Provided counsel to a number of Barclays employees potentially implicated in the SFO investigation into the bank's capital-raising practices in Qatar.

Notable practitioners

Louise Hodges provides deeply experienced counsel to clients facing allegations of financial crime, with a particular specialism in representing individuals from the financial services industry. Commentators suggest that she is "extraordinarily hard-working," as well as noting that she is "extraordinarily knowledgeable, very grounded and pragmatic."

Commentators describe Eve Giles as "somebody you want on your side," praising her as "very effective and committed to clients." She continues to represent individuals in a number of high-profile SFO investigations, including several clients involved in alleged rate-fixing.

Jonathan Grimes has a growing practice advising individuals involved in criminal investigations into matters including corruption and insider dealing. According to one commentator, "he fights hard for clients and leaves no stone unturned."

Interviewees commend Stephen Parkinson as "understated and highly intelligent," highlighting his "great and clear grasp of strategy." He runs the firm's criminal litigation team and acts for individuals and corporates facing investigation on a range of white-collar matters.

Department profile by Kingsley Napley LLP

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Mishcon de Reya LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 2 partners
- 5 other qualified lawyers

What the team is known for Fast-growing team with a broad-based financial crime offering. Fields notable expertise in anti-bribery and corruption matters as well as a strong private prosecution practice.

Strengths Interviewees say: "They seem to be expanding hugely in this area and have really carved out a space for themselves."

Clients say: "They were frank about everything, they were upfront, they were very transparent and sought my thoughts on everything, so it was a participatory way of going about things. They were just responsive and good at what they did. The bottom line is that they are consummate professionals."

Work highlights Secured an acquittal at trial for Jack Flader, who had been prosecuted by the SFO for money laundering for his alleged his role in a EUR100 million boiler-room fraud.

Notable practitioners

Barrister Alison Levitt QC heads the firm's business crime department and specialises in bringing private prosecutions in financial crime. Interviewees say she "likes to get good results for her clients and cares about the work."

The "very passionate and hard-working" Jo Rickards is widely regarded as a major force in the financial crime market. She has recently moved to the firm from Kingsley Napley, bringing a broad-based expertise and a strong record of acting on high-profile corruption cases.

Richard Cannon is an experienced white-collar practitioner who has recently joined the firm from Janes Solicitors. Interviewees highlight the combination of "personality and forensic, analytical skill," as well as noting that "he goes over and above to ensure that clients are well looked after."

Department profile by Mishcon de Reya LLP

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Norton Rose Fulbright - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 33 partners
- 105 other qualified lawyers

What the team is known for Robust white-collar crime team with the capacity to handle complex international fraud, corruption and regulatory investigations. Routinely advises global companies and high net worth individuals on criminal misconduct in the banking and financial services industries. Continues to attract mandates in high-profile market manipulation matters. Extensive international network makes it a strong choice for cross-border investigations and proceedings in multiple jurisdictions.

Work highlights Represented Carl Rogberg, the former finance director of Tesco, who was charged by the SFO following its investigation into the company's alleged overstatement of profits.

Provided counsel to a former senior executive at the Chief Investment Office of J.P. Morgan on multi-jurisdictional criminal and regulatory investigations into alleged securities fraud.

Notable practitioners

The "extremely talented" Neil O'May is a financial crime practitioner who is widely lauded for his ability to "deal with anything that comes his way." Commentators describe him as "an intelligent guy who clearly gives a lot of thought to the instructions he receives," with one source saying: "He has a masterful grasp of strategy without losing grasp of the detail."

Department profile by Norton Rose Fulbright

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Peters & Peters Solicitors LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 5 partners
- 13 other qualified lawyers

What the team is known for Outstanding financial crime practice, and one of the earliest firms to establish itself in this field. Enviable experience advising individuals on an array of business crime issues, including cartel, bribery and money laundering matters. Also noted for its growing private prosecution practice.

Strengths Interviewees say: "Peters & Peters is an excellent criminal law boutique with top expertise in handling international business and financial crime cases."

Sources describe it as "one of the best firms," noting its private prosecution experience and its "very reasonable and balanced approach."

Work highlights Acted for Tony Mace, the former CEO of a Dutch energy company, who is alleged to have paid bribes to Petrobras employees. He faced criminal charges in Brazil and an investigation by the DOJ into potential violations of the Foreign Corrupt Practices Act.

Represented Richard Boath, a former senior executive at Barclays, in relation to the SFO investigation into the bank's activities in Qatar.

Notable practitioners

Monty Raphael QC offers unparalleled experience in white-collar crime, having acted on the full range of cases. His notable recent work includes multi-jurisdictional corruption and money laundering investigations. Commentators note his "astute legal mind," with one interviewee describing him as "one of the cleverest and most talented people I have ever worked with."

Interviewees describe Michael O'Kane as "an outstanding lawyer in international economic criminal law," with "top expertise in international corruption procedures and economic sanctions." He is a senior partner at the firm and heads its business crime department.

Neil Swift advises clients involved in cross-border investigations into alleged corruption and money laundering, as well as domestic proceedings involving the SFO and FCA. Sources say he is "quietly impressive and inspires confidence."

Jasvinder Nakhwal is experienced in advising individuals charged with cartel-related financial crimes. Sources describe her as "bright, proactive and easy to work with."

Department profile by Peters & Peters Solicitors LLP

Peters & Peters is recognised for its “outstanding global financial crime practice that is frequently called upon to act in significant cases”. Four decades ago, we were the first UK practice to develop a specialist white-collar crime team and we remain at the cutting-edge of the discipline to this day. Our substantial experience encompasses all manner of business crime issues, including; multi-jurisdictional criminal and financial regulatory investigations, fraud, bribery and corruption, cartels/competition law, tax, sanctions, private prosecutions and restraint and confiscation. The department’s unparalleled expertise in related public law matters – including challenges to EU sanctions, Interpol Red Notices and extradition proceedings both in the UK and overseas – enables us to advise companies and individuals on the most complex and sensitive cases that arise in an increasingly regulated international business arena. The business crime team works closely with our colleagues in the firm’s award-winning Commercial Litigation and Civil Fraud department to provide an exceptional service to clients whose cases demand an in-depth analysis of both criminal and civil liability.

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Shearman Bowen & Co - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 4 partners
- 6 other qualified lawyers

What the team is known for Boutique crime firm renowned for astute defence of charges relating to financial crime and Proceeds of Crime Act matters. Draws mandates from private clients on an impressive range of matters, including high-stakes money laundering and corruption proceedings against the SFO.

Strengths Interviewees say: "They really know how to handle private cases and they understand how to go the extra mile."

Sources say: "For quite a small firm they have a fantastic presence in the marketplace."

Work highlights Successfully defended James Campbell Sutherland, the head of a fiduciary company charged by the SFO with money laundering over £70 million.

Represented Raj von Badlo, who faced FCA charges of involvement in an unregulated foreign exchange investment fraud worth £5.5 million. Negotiated a plea and acted in resulting confiscation proceedings, limiting the confiscation to less than £100,000.

Notable practitioners

Mark Bowen is a "thoroughly good, diligent, intelligent and subtle solicitor," according to market sources, who add that he provides "impressive service, and is well respected and well liked in the business." He has substantial experience representing professionals and corporate executives in major investigations.

Department profile by Shearman Bowen & Co

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Stephenson Harwood LLP - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 7 partners
- 22 other qualified lawyers

What the team is known for Respected financial crime practice that defends individuals in major investigatory proceedings and in internal investigations. Has built an enviable profile acting for current and former employees of financial institutions, in relation to allegations of illegal rate manipulation. Draws on noted regulatory expertise to provide a well-integrated service to clients from the financial services sector.

Strengths One source comments: "Stephenson Harwood is extremely well known in the market for regulatory investigations and financial crime, and has been involved in many of the high-profile disputes of recent years."

Work highlights Acted for Peter Johnson, a former Barclays employee who was prosecuted by the SFO for his role in the rigging of the US dollar Libor rate.

Represented Joerg Vogt, a former Deutsche Bank trader who was responsible for the submission of bank's daily Euribor rates. The SFO sought to extradite him to the UK, and to charge him for his alleged role in the manipulation of the rate.

Notable practitioners

Market commentators recommend Tony Woodcock as "a highly knowledgeable and very sophisticated financial services and criminal lawyer," noting that he has a "very light touch hiding a massive wealth of experience."

Department profile by Stephenson Harwood LLP

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Tuckers Solicitors - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 6 partners
- 70 other qualified lawyers

What the team is known for Highly esteemed criminal law boutique with an enviable reputation advising on both legally-aided and privately funded matters. Active in the defence of fraud claims and regulatory investigations. Draws mandates on a number of high-profile FCA prosecutions.

Strengths Clients describe the team as "incredible," adding: "They are extremely thorough."

Work highlights Advised a former senior executive at Rolls-Royce on their potential implication in the SFO's investigation into alleged bribery and corruption at the company.

Represented Surrinder Sappal, who was charged by the FCA with insider dealing for his alleged role in the use of inside information to profit from trading in shares of Logica before its takeover by CGI Group Holdings. He was acquitted at trial.

Notable practitioners

Richard Egan is an experienced criminal solicitor with a strong record of handling high-profile financial crime investigations. Clients describe him as a "real tactician" and an "incredibly astute solicitor."

Philip Smith is a well-regarded fraud practitioner, with notable recent experience in film tax fraud and land-banking fraud. Interviewees describe him as a "skilful operator who knows what to do and when."

Jim Meyer is a respected white-collar lawyer whose recent work includes defending a number of FCA prosecutions. An interviewees describes him as "the perfect man for a fact-heavy, technical case," saying: "You need him on your side. I've never known anyone work as hard as him – he lives it."

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WilmerHale - Financial Crime: Individuals

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Commentary from the Chambers UK guide

Basic facts about the department
- 1 partner
- 7 other qualified lawyers

What the team is known for Well-regarded financial crime practice with an impressive record of acting on high-stakes SFO investigations. Acts on the full range of matters in this area, fielding experience in fraud, corruption, insider dealing and rate-fixing. Enviable client base includes mandates from sector-leading energy and financial services institutions.

Strengths Interviewees say: "WilmerHale have a depth and breadth of capability which impresses. There is an assured calm which readily transmits to the client and a steely resolve which makes one feel glad they are on your side."

Commentators add: "In terms of international firms WilmerHale has one of the strongest teams around."

Notable practitioners

Stephen Pollard is widely regarded as "the best current white-collar crime solicitor that there is." He boasts an impressive record of acting on many of the most high-profile and complex SFO investigations, especially in bribery and corruption matters. Sources say: "He is unparalleled in terms of his practice – he has been in all the main cases, is just fantastic with clients, cuts through everything, and tactically is really good. He's just incredibly impressive in all areas."

Elly Proudlock has a fast-growing reputation for representing individuals facing SFO investigations into offences including corruption and money laundering. Sources describe her as "extremely bright and hard-working," and clients commend her as a "good lawyer with a very analytical mind."

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Overview

FINANCIAL CRIME: Individuals

Following last year’s varied outcomes in the LIBOR prosecutions, six traders now await trials in January 2018 in relation to allegations that they tried to manipulate EURIBOR. It will be interesting to see whether the SFO can improve on its success rate against a backdrop of confusion and criticism as to how to prove dishonesty in circumstances where the rules in place at the time permitted the conduct that is subsequently alleged to be a conspiracy to defraud.

In June 2017, the SFO charged Barclays plc in relation to emergency cash calls at the height of the financial crisis in 2008, and the bank’s advisory services agreement with Qatar. Furthermore, four individuals formerly with Barclays face various counts of fraud by false representation and conspiracy to commit fraud in relation to Barclays’ capital raising in 2008, with a criminal trial set for January 2019. One of the individuals was the former global bank CEO of Barclays in 2008, and the prosecution sees the first global chief executive of a bank to face criminal charges arising from the financial crisis. If the SFO are successful, this could be the start of a chain of further prosecutions arising from the 2008 financial crisis.

The past year saw the conclusion of Operation Tabernula, the FCA’s largest and most complex insider dealing investigation. The proceedings resulted in three acquittals and two convictions, with custodial sentences of three and a half and four and a half years in prison respectively, the latter being the longest custodial sentence for insider dealing in a case prosecuted by the FCA. The FCA’s focus on insider dealing continues to grow. In June 2017, two former UBS compliance officers were charged with insider dealing offences for passing on information between 2013 and 2014. This is a result of the FCA’s push to exercise its criminal powers more in the past year; the number of insider-dealing cases that the FCA is currently dealing with is over 70.

Following the successful conclusion of three deferred prosecution agreements (“DPAs”) in the past year – XYZ in July 2016, Rolls-Royce plc in January 2017, and Tesco Stores Ltd in April 2017 – the investigations and prosecutions of implicated individuals is now anticipated with interest. Widespread concerns having been expressed about potential unfairness; and without commenting on any one in particular, the pragmatic nature of the DPA route means that it might have been entered into for ‘commercial’ reasons and likely without regard for the implications on individuals in any subsequent prosecutions. Further, DPAs involve the organisation’s acceptance of a statement of facts, which may include admissions; and organisations seeking a DPA may find an advantage in dismissing former management and directing the blame at them. Former employees would not be party to and would have no visibility of the DPA proceedings. Further, they would have no right to make representations in respect of maintaining their anonymity. Importantly, the need for co-operation is likely to involve the organisation disclosing records of internal interviews, irrespective of legal privilege. While such an approach is helpful to an organisation intent on quick resolution and avoiding the risk of criminal conviction, the employees will rightly be concerned that such interviews were effectively under compulsion, if they were still employed at the time (and wished to remain in employment); and in any event are likely to have been undertaken in the absence of a formal caution. The widespread publicity surrounding the DPAs will only have increased the risk of unfairness and it will be interesting to see how the issues of fairness and admissibility are resolved at the forthcoming trials.

There has been one development in financial crime which will give individuals and organisations alike some cheer: the practice of law enforcement encouraging banks to end customer relationships by reducing account balances to a cheque or banker’s draft, which may be seized and ultimately forfeited pursuant to ‘cash’ seizure powers, has been declared unlawful by the High Court in Merida Oil Traders Ltd. Such action enabled officers to seize funds from bank accounts sometimes in the tens of millions of pounds, with nothing more than an officer’s belief that there were reasonable grounds to suspect that it derived from or was to be used in unlawful conduct. And while a magistrates’ court had to sanction the continued detention of cash within 48 hours, unless the subject of the seizure is in a position to oppose it, this was usually a formality.

The ‘innovation’ by law enforcement was particularly ripe for abuse in the context of money laundering, a complex offence which can be committed with nothing more than ‘suspicion’ that a person is dealing with the proceeds of crime (and ultimately proof that the property is the proceeds of crime). In the context of banking relationships, any number of factors might give rise to ‘suspicions’, including unusual or unexplained transactions or activity on the account and any enquiry by the police, whether reasonable or not, and whether directly into the customer or merely in respect of a person with whom they have dealt. The upshot was that individuals or businesses who crossed law enforcement’s radar, whether following the filing of a suspicious activity report by the bank or otherwise, risked having the entire contents of their bank accounts seized on a ‘hunch’. Following Merida Oil, and as was intended by Parliament, law enforcement will have to conduct a substantive criminal investigation; and if they want to prevent the money from being dissipated in the meantime, they will have to apply to the Court for a restraint or freezing order, where expert judicial scrutiny can be applied.

However, such is the current climate, Parliament is now rowing back on these protections. When the Criminal Finances Act comes into force, law enforcement officers with reasonable grounds for suspecting that £1,000 or more held in a bank or building society account represents the proceeds of crime, or is intended for use in crime, will be able to apply to a magistrates’ court for a freezing order in relation to the account (without notice in certain circumstances) and, within two years, for the money held in the frozen account to be forfeited. Crucially, there is no provision for a maximum amount. As the government and courts have repeatedly stated, in complex matters there should be a high level of scrutiny by a judge with an appropriate degree of expertise who will be able to balance the public interest of the impact on crime with the rights of those who may be affected. That is unlikely to be found via summary justice in the magistrates’ courts.

FINANCIAL CRIME: An Introduction to UK-wide Contributed by Richard Sallybanks, BCL Solicitors LLP
FINANCIAL CRIME: Cartel Investigations (July 2017)

Previous overviews have commented on a lack of enforcement activity in relation to the cartel offence in section 188 of the Enterprise Act 2002 and this trend continues in relation to criminal enforcement under both the original section 188 offence requiring dishonesty and under the (not so) “new offence”, amended by section 47 of the Enterprise and Regulatory Reform Act 2013 (in force from 1 April 2014 and not retrospective), which no longer requires the Competition and Markets Authority (“CMA”) to prove dishonesty.

The CMA’s website contains details of only one ongoing criminal case. This is in relation to the supply of precast concrete drainage products, an investigation which opened on 12 March 2013 and, as such, an investigation under the original section 188 offence. On 21 March 2016 one individual pleaded guilty and (at the time of writing) still awaits sentencing. Notwithstanding that guilty plea, the investigation continued into other suspects, but on 13 June 2017 the CMA announced that there was insufficient evidence to prosecute any other individuals in this investigation, and so the last remaining criminal case being investigated by the CMA under the old offence is almost at an end.

According to the CMA’s website, there are no live criminal cartel investigations under the “new offence”. Given that there was an anticipated upturn in the number of criminal cartel investigations, prosecutions and, ultimately, convictions following the introduction of the “new offence” and the removal of the requirement to prove dishonesty, the absence of any investigations in the three years since the new offence came into force (at least in the public domain) does not reflect well on the CMA.

Over fourteen years after section 188 came into force (June 2003), the CMA has had three successful prosecutions. The first was the “Marine Hose” case in 2008 (prosecuted by the CMA’s predecessor, the Office of Fair Trading) in which three British businessmen pleaded guilty to the section 188 offence as part of an agreement with the Antitrust Division of the US Department of Justice (having also entered guilty pleas in the US where they had been arrested) which enabled them to return to England to serve their prison sentences here. The second was the galvanised steel tank prosecution in 2015 which resulted in one defendant pleading guilty and assisting the CMA as a cooperating witness (two other defendants being acquitted at trial), and the third is the prosecution of a defendant in the case involving the supply of precast concrete drainage products referred to above.

The CMA’s Annual Plan 2017/18 published in March 2017 states in respect of their criminal investigations: “Our approach to the criminal cartel offence is guided by lessons learned from the galvanised steel tanks trial in 2015, where those defendants who were found ‘not guilty’ based their defence solely on the grounds that they had not acted ‘dishonestly’, and also on the fact that the law has now been changed so that, for conduct from April 2014 onwards, there is no longer a requirement for the CMA to prove that individuals acted dishonestly to establish the offence. We take a pragmatic view about launching criminal cases where the activity occurred before April 2014. Although they are, all other things being equal, more difficult to prosecute, we note that in the past two years, in two different cases, individuals have pleaded guilty in respect of pre-April 2014 activity. We are actively considering the launch of other cases involving cartel activity from April 2014 onwards, on the basis of ongoing intelligence work.”

However, the CMA’s criminal enforcement work features less prominently than their competition and consumer work in the Annual Plan which perhaps reflects their pragmatism. They do nevertheless say that a key commitment is to “open new criminal investigations and pursue prosecutions as appropriate, having regard to lessons from our most recent cases as well as the change in the law in respect of cartel activity occurring from April 2014.” It remains to be seen if their ongoing intelligence work bears fruit over the coming year but the fact remains that, since January 2014, no new criminal cartel investigations have been opened – does this suggest that no businesses are involved in cartel activity (which the CMA would say was not the case) or rather that the CMA appear to lack intelligence leads or investigative capabilities in this area?

Although not part of the CMA’s criminal enforcement work, a feather in the cap for the CMA last year was the disqualification of the Managing Director of Trod Ltd, a party to a price collusion cartel, for which they had issued an infringement decision in August 2016. The Managing Director was disqualified from acting as a director for five years in November 2016, “reflecting the fact that he had personally contributed to the breach of competition law.” These powers have been available to the CMA since 2003, but were used for the first time in this case.

In relation to prosecutions, one key issue for the CMA is how they make use of immunised witnesses and assisting/cooperating offenders as part of their leniency programme in criminal cartel investigations and prosecutions. The fact that a company and/or individuals can receive immunity from sanction and prosecution provided they meet certain conditions, including informing the CMA of the conduct before it has knowledge, admitting participation in the cartel conduct, and providing complete cooperation, can be attractive and encourages whistleblowing. However, the CMA readily acknowledge (see speech by Stephen Blake, Senior Director - Cartels and Criminal Group on 13 November 2015) that the immunity/cooperation process can be a double-edged sword as juries are prone to distrust the motives of immunised/cooperating witnesses who will have either avoided prosecution entirely or are hoping to secure a more lenient sentence. This may have been a factor in the acquittal of the galvanised steel defendants. However, the CMA will continue to use the leniency programme as they say it plays an important role in the investigation of cartels, but they will certainly have to consider very carefully how any immunised/cooperating witness is used in future prosecutions.

Despite the lack of live investigations, the fact remains that the removal of the dishonesty element does make it easier for the authorities to establish the criminal cartel offence. The CMA will no doubt be looking to use its intelligence and enforcement capability in the years ahead to establish its credentials, both domestically and internationally, as a credible and effective enforcement agency. Employees and directors must therefore continue to take seriously the risk of investigation, prosecution and (as the sentencing comments in the galvanised steel case demonstrated) likely imprisonment, and any individual caught up in such an investigation, or company lawyer looking to arrange representation for individuals who may have a personal criminal exposure, would be well-advised to seek specialist criminal law advice from one of the firms featured in the following table.

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Eminent Practitioner

Peters & Peters Solicitors LLP

From the Chambers UK guide

Monty Raphael QC offers unparalleled experience in white-collar crime, having acted on the full range of cases. His notable recent work includes multi-jurisdictional corruption and money laundering investigations. Commentators note his "astute legal mind," with one interviewee describing him as "one of the cleverest and most talented people I have ever worked with."

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Star Individuals

WilmerHale

From the Chambers UK guide

Stephen Pollard is widely regarded as "the best current white-collar crime solicitor that there is." He boasts an impressive record of acting on many of the most high-profile and complex SFO investigations, especially in bribery and corruption matters. Sources say: "He is unparalleled in terms of his practice – he has been in all the main cases, is just fantastic with clients, cuts through everything, and tactically is really good. He's just incredibly impressive in all areas."

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Band 1

Corker Binning

From the Chambers UK guide

Peter Binning wins widespread plaudits for his work defending individuals from high-profile fraud and corruption charges. One source reports: "In that particular field of representing senior corporate individuals, he is clever, has great judgement and is a really great tactician," adding that "he has that tactical nous as well as the bedside manner – it's a killer combination."

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Band 1

BCL Solicitors LLP

From the Chambers UK guide

Ian Burton is a deeply experienced white-collar practitioner whose recent work includes a number of international anti-corruption matters. Sources commend him as a "rainmaker extraordinaire" who "picks up clients of the highest level."

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Band 1

Corker Binning

From the Chambers UK guide

According to commentators, David Corker "has led some big shifts in thinking" in the field, maintaining his long-standing reputation as "a fantastic criminal defence lawyer used to operating in a corporate space." His top-drawer white-collar practice sees him act for individual clients under investigation by bodies including HMRC, the SFO and the FCA.

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Band 1

Herbert Smith Freehills

From the Chambers UK guide

Rod Fletcher serves as head of the corporate crime and investigations department at Herbert Smith Freehills and acts for individuals involved in high-stakes SFO investigations. Impressed market commentators describe him as "absolute class."

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Band 1

Simmons & Simmons LLP

From the Chambers UK guide

Stephen Gentle of Simmons & Simmons LLP offers a wealth of experience in the defence of individuals facing both domestic and international investigations for alleged fraud, money laundering and corruption. Sources say that "his experience and ability to identify the issues and relate them to clients is very impressive."

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Band 1

BCL Solicitors LLP

From the Chambers UK guide

Jane Glass is a long-standing fraud practitioner with a wide range of experience in the defence of government investigations into individuals. Sources commend her "fantastic presence and intellect."

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Band 1

Kingsley Napley LLP

From the Chambers UK guide

Louise Hodges provides deeply experienced counsel to clients facing allegations of financial crime, with a particular specialism in representing individuals from the financial services industry. Commentators suggest that she is "extraordinarily hard-working," as well as noting that she is "extraordinarily knowledgeable, very grounded and pragmatic."

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Band 1

Norton Rose Fulbright

From the Chambers UK guide

The "extremely talented" Neil O'May is a financial crime practitioner who is widely lauded for his ability to "deal with anything that comes his way." Commentators describe him as "an intelligent guy who clearly gives a lot of thought to the instructions he receives," with one source saying: "He has a masterful grasp of strategy without losing grasp of the detail."

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Band 1

Stephen Parkinson

Kingsley Napley LLP

From the Chambers UK guide

Interviewees commend Stephen Parkinson as "understated and highly intelligent," highlighting his "great and clear grasp of strategy." He runs the firm's criminal litigation team and acts for individuals and corporates facing investigation on a range of white-collar matters.

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Band 1

Richard Sallybanks

BCL Solicitors LLP

From the Chambers UK guide

Commentators describe Richard Sallybanks as "calm, experienced and highly able," with one source noting that "he is extremely thorough, his judgement is excellent and his client handling is superlative." He provides expert counsel to senior executives on a range of criminal fraud matters, including corruption, money laundering and accounting fraud.

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Band 1

Herbert Smith Freehills

From the Chambers UK guide

Brian Spiro joined Herbert Smith Freehills from BCL Solicitors in 2017. He has extensive expertise advising clients charged with financial crime, with notable experience in rate-fixing matters. Sources suggest that he is "one of the best operatives around," noting that "clients absolutely adore him because he is completely straight with them."

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Band 1

BCL Solicitors LLP

From the Chambers UK guide

Harry Travers maintains a wide-ranging practice defending clients from allegations of corruption, as well as other financial crime charges. He wins acclaim from commentators as a "relentless litigator" with a "tremendous analytical mind" and "great client skills."

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Band 2

Anthony Barnfather

Barnfather Solicitors

From the Chambers UK guide

Anthony Barnfather is the founding partner Barnfather Solicitors and an expert in fraud and financial crime, with a particular recent focus on high-value tax fraud investigations. Sources describe him as a "really great and very intuitive lawyer" and report that "clients love him."

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Band 2

Brown Rudnick LLP

From the Chambers UK guide

Sources describe Mark Beardsworth as "a strong communicator with great networking skills" who is "able to grasp highly complex matters very quickly." He displays extensive experience in defending directors facing allegations including rate-fixing and corruption.

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Band 2

Eversheds Sutherland

From the Chambers UK guide

Neill Blundell of Eversheds Sutherland is a highly experienced fraud solicitor with a strong record of defending individuals in proceedings prosecuted by bodies including HMRC and the SFO. Clients praise his balance of skills, saying: "He applies rational logic and legal insights into situations but is also empathetic to the stress on individuals."

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Band 2

Fox Williams LLP

From the Chambers UK guide

James Carlton of Fox Williams LLP has an extensive practice in financial crime with a particular focus on handling market manipulation cases for individual clients from the financial services industry. Sources say he has "real gravitas," adding that he is "very good at working his way through to the heart of a case."

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Band 2

Cooley LLP

From the Chambers UK guide

Louise Delahunty of Cooley LLP is a financial crime expert with a great deal of experience representing senior executives and officers facing investigation by the SFO and other bodies. Sources say that she is "incredibly thoughtful," as well as being "tenacious when it comes to protecting her clients."

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Band 2

Brown Rudnick LLP

From the Chambers UK guide

Tom Epps wins praise for his representation of senior executives involved in SFO investigations into fraud, corruption and other financial crimes. In the words of one source, he "stands out for his rigour, candour and ability to separate major and minor issues."

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Band 2

Matthew Frankland

Byrne and Partners LLP

From the Chambers UK guide

Matthew Frankland is a seasoned white-collar lawyer with notable recent experience representing individuals involved in alleged rate-fixing. Sources describe him as "one of these quiet, unsung heroes of the white-collar crime area," noting that he "does very high-quality work and does it well." Others consider him "a real go-to guy who is very easy to work with whether you're with or against him."

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Band 2

Kingsley Napley LLP

From the Chambers UK guide

Commentators describe Eve Giles as "somebody you want on your side," praising her as "very effective and committed to clients." She continues to represent individuals in a number of high-profile SFO investigations, including several clients involved in alleged rate-fixing.

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Band 2

Janes Solicitors

From the Chambers UK guide

The "immensely experienced" David Janes is widely regarded as an "extremely astute tactician" with an impressive record in the full range of financial crime matters. Clients describe him as an "exceptionally clear thinker," with one source highlighting his ability to "find avenues that other lawyers seemed not even to be aware of."

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Band 2

Peters & Peters Solicitors LLP

From the Chambers UK guide

Interviewees describe Michael O'Kane as "an outstanding lawyer in international economic criminal law," with "top expertise in international corruption procedures and economic sanctions." He is a senior partner at the firm and heads its business crime department.

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Band 2

Byrne and Partners LLP

From the Chambers UK guide

The "superb" Michael Potts is held in high regard for his wide-ranging practice in financial crime, which includes representing individuals facing insider dealing and corruption charges. Sources say that he "gives clear advice – even on difficult conceptual matters that require careful thought to lay out, he always does it in a clear and well-structured way." 

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Band 2

Mishcon de Reya LLP

From the Chambers UK guide

The "very passionate and hard-working" Jo Rickards is widely regarded as a major force in the financial crime market. She has recently moved to the firm from Kingsley Napley, bringing a broad-based expertise and a strong record of acting on high-profile corruption cases.

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Band 2

Howard Kennedy LLP

From the Chambers UK guide

Ian Ryan is widely recognised as a "very experienced fraud and criminal lawyer with excellent judgement and tactical skills." His extensive financial crime practice includes a great deal of rate-fixing work. Sources describe him as a "really good tactician" who is "hard-working and very well respected."

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Band 2

Stephenson Harwood LLP

From the Chambers UK guide

Market commentators recommend Tony Woodcock as "a highly knowledgeable and very sophisticated financial services and criminal lawyer," noting that he has a "very light touch hiding a massive wealth of experience."

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Band 3

Simons Muirhead & Burton

From the Chambers UK guide

Anthony Burton is a senior partner at Simons Muirhead & Burton and a veteran practitioner in fraud and financial criminal defence. He has represented individuals in proceedings ranging from art fraud to accounting fraud.

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Band 3

Byrne and Partners LLP

From the Chambers UK guide

David Byrne has deep financial crime experience, with a strong track record of representing clients under investigation by bodies including the SFO and HMRC. According to commentators, "he is authoritative and bold, tenacious and inventive, and he stands firmly for his client."

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Band 3

Mishcon de Reya LLP

From the Chambers UK guide

Richard Cannon is an experienced white-collar practitioner who has recently joined the firm from Janes Solicitors. Interviewees highlight the combination of "personality and forensic, analytical skill," as well as noting that "he goes over and above to ensure that clients are well looked after."

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Band 3

Richard Cornthwaite

Cartwright King

From the Chambers UK guide

Market commentators describe Richard Cornthwaite as "vastly experienced and super well connected." He is a financial crime veteran with a wide-ranging practice that includes defending individuals charged with fraud, corruption and insider dealing.

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Band 3

Blackfords LLP

From the Chambers UK guide

Daniel Cundy is a respected financial crime practitioner with a particular strength in handling high-value HMRC investigations. Interviewees suggest that "his knowledge of the way financial markets and crime work is really quite exceptional," noting: "He is particularly good at pre-trial abuse and disclosure."

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Band 3

Slater and Gordon Lawyers

From the Chambers UK guide

Shula de Jersey serves as head of business crime at Slater and Gordon Lawyers, where she acts for individuals facing allegations including corruption, money laundering and market manipulation. One source says: "I know her to be an excellent practitioner, who is very good and experienced, and very good with clients."

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Band 3

Hickman & Rose

From the Chambers UK guide

Ross Dixon wins recognition from interviewees as an "absolutely excellent" white-collar solicitor who is "low-key but very on the money." He offers a great deal of recent experience acting for individual clients under investigation by the SFO for alleged bribery and corruption offences.

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Band 3

BCL Solicitors LLP

From the Chambers UK guide

Michael Drury draws on his national security background to provide expert counsel to clients in extradition cases, as well as international financial crime more broadly. Sources describe him as "an intellectual heavyweight whose points run a coach and horses through the other side."

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Band 3

Tuckers Solicitors

From the Chambers UK guide

Richard Egan is an experienced criminal solicitor with a strong record of handling high-profile financial crime investigations. Clients describe him as a "real tactician" and an "incredibly astute solicitor."

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Band 3

Hickman & Rose

From the Chambers UK guide

Andrew Katzen maintains a well-regarded practice in the representation of clients under investigation for criminal fraud. Sources commend his "very sensible approach to his cases."

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Band 3

Taylor Wessing LLP

From the Chambers UK guide

David McCluskey serves as head of crime at Taylor Wessing LLP and represents individuals facing SFO and multi-jurisdictional investigations on matters such as bribery and money laundering. Interviewees say he is a "brilliant lawyer," describing him as "very straightforward, very pragmatic and client-minded."

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Band 3

Tuckers Solicitors

From the Chambers UK guide

Jim Meyer is a respected white-collar lawyer whose recent work includes defending a number of FCA prosecutions. An interviewees describes him as "the perfect man for a fact-heavy, technical case," saying: "You need him on your side. I've never known anyone work as hard as him – he lives it."

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Band 3

Elizabeth Robertson

Skadden, Arps, Slate, Meagher & Flom (UK) LLP

From the Chambers UK guide

Elizabeth Robertson is an "exceptional" white-collar crime expert at Skadden, Arps, Slate, Meagher & Flom (UK) LLP. She is highly capable of representing senior executives facing financial criminal charges or investigations. Clients appreciate that she "gives complete assurance that things will be done right."

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Band 3

Howard Kennedy LLP

From the Chambers UK guide

Kevin Robinson has recently moved to Howard Kennedy from Morgan, Lewis & Bockius. His wide-ranging white-collar practice includes significant experience in handling criminal cartel matters. Sources commend his "immaculate judgement," adding that "his strategic approach both before charge and at trial is frankly unmatched."

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Band 3

Hickman & Rose

From the Chambers UK guide

Ben Rose is an experienced practitioner in this space, with an impressive record of acting for clients accused of offences including bribery and market manipulation. He has recently handled a number of cross-border matters involving regulators in multiple jurisdictions.

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Band 3

Corker Binning

From the Chambers UK guide

Andrew Smith draws on complementary expertise in extradition and confiscation to provide counsel to clients on criminal charges including money laundering and insider dealing. Commentators say that "he is very responsive and very energetic in the way he approaches a problem," as well as "a real pleasure to deal with."

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Band 3

Tuckers Solicitors

From the Chambers UK guide

Philip Smith is a well-regarded fraud practitioner, with notable recent experience in film tax fraud and land-banking fraud. Interviewees describe him as a "skilful operator who knows what to do and when."

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Band 3

Osborne Clarke LLP

From the Chambers UK guide

Interviewees recommend Jeremy Summers of Osborne Clarke LLP as "a clever lawyer who has had a specialist practice in commercial crime for decades." His wide-ranging international practice sees him represent individuals facing investigation by the SFO, the FCA and foreign agencies, as well as private prosecutions.

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Band 3

Irwin Mitchell

From the Chambers UK guide

The "clever and highly committed" Sarah Wallace wins recognition from interviewees for her "good client care skills." She is an experienced practitioner with a strong record of advising on matters at the intersection of financial crime and regulatory proceedings.

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Band 4

Janes Solicitors

From the Chambers UK guide

Simon Barker represents individual clients facing a wide range of financial crime charges, with notable recent experience in tax and contract fraud, as well as market manipulation. Interviewees say: "He is extremely diligent and builds a great rapport with clients."

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Band 4

Bark & Co

From the Chambers UK guide

Giles Bark-Jones founded the firm and continues to serve as its principal. He maintains a strong financial crime practice, with a notable record of handling SFO investigations into alleged fraud, corruption and money laundering. One source says: "He is really go-getting – I loved working with him."

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Band 4

Blackfords LLP

From the Chambers UK guide

Market commentators describe Gary Bloxsome as a "strategic thinker" with a "big client base" in financial crime. He serves as head of the firm's criminal team and advises on a wide range of fraud charges, including those relating to vishing and carbon credit matters.

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Band 4

Shearman Bowen & Co

From the Chambers UK guide

Mark Bowen is a "thoroughly good, diligent, intelligent and subtle solicitor," according to market sources, who add that he provides "impressive service, and is well respected and well liked in the business." He has substantial experience representing professionals and corporate executives in major investigations.

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Band 4

Brett Wilson LLP

From the Chambers UK guide

Sources describe Nick Brett as "a genuine specialist in financial crime and fraud" and commend his dedication: "He is dogged and tireless in his support of and advocacy for his clients, and is the sort of solicitor that anyone would be lucky to have in their corner." He is a name partner at Brett Wilson LLP.

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Band 4

Kobre & Kim

From the Chambers UK guide

Roger Burlingame of Kobre & Kim provides expert advice to clients facing US and multi-jurisdictional white-collar investigations into matters such as corruption and market abuse. Interviewees describe him as "the go-to guy for any case with a US angle."

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Band 4

Russell-Cooke

From the Chambers UK guide

Jae Carwardine of Russell-Cooke has a broad white-collar criminal defence practice, representing individuals in a wide variety of fraud cases. One source describes her as "an extremely polished, professional lawyer who has a good strategic mind in relation to business crime and fraud," adding that she is "extremely tenacious, driven, and pays an immense amount of attention to detail."

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Band 4

Blackfords LLP

From the Chambers UK guide

Trevor Francis is the managing partner of the firm and an experienced criminal lawyer. His financial crime practice spans from corruption to insider dealing prosecutions by bodies including the SFO, HMRC and the FCA.

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Band 4

Kingsley Napley LLP

From the Chambers UK guide

Jonathan Grimes has a growing practice advising individuals involved in criminal investigations into matters including corruption and insider dealing. According to one commentator, "he fights hard for clients and leaves no stone unturned."

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Band 4

Mishcon de Reya LLP

From the Chambers UK guide

Barrister Alison Levitt QC heads the firm's business crime department and specialises in bringing private prosecutions in financial crime. Interviewees say she "likes to get good results for her clients and cares about the work."

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Band 4

Lewis Nedas Law

From the Chambers UK guide

Jeffrey Lewis is a founding partner of Lewis Nedas Law and the head of its fraud department. Commentators describe him as a "great guy and a great lawyer." 

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Band 4

Corker Binning

From the Chambers UK guide

Jessica Parker enjoys a growing reputation for her white-collar practice, which has recently included a particular focus on corruption. Sources report that "she is very cool and collected," as well as demonstrating "a model of very good client care, rolling up her sleeves and immersing herself in the case."

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Band 4

Jonathan C Pickworth

White & Case LLP

From the Chambers UK guide

Jonathan Pickworth heads the London white-collar group at White & Case LLP. He is a highly regarded practitioner whose diverse client base includes senior executives from a range of industries, facing charges including bribery and accounting fraud.

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Band 4

Bindmans LLP

From the Chambers UK guide

Martin Rackstraw is an experienced criminal solicitor with a notable record of advising clients involved in SFO investigations. Interviewees commend him as a "good legal analyst" and an "excellent lawyer who brings his legal skills right out to the forefront of what he is doing."

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Band 4

Simons Muirhead & Burton

From the Chambers UK guide

Pamela Reddy of Simons Muirhead & Burton works extensively in fraud and financial crime, drawing a number of senior clients from the financial services industry. Sources commend her "great judgement," adding that "she works hard for her clients."

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Band 4

Peters & Peters Solicitors LLP

From the Chambers UK guide

Neil Swift advises clients involved in cross-border investigations into alleged corruption and money laundering, as well as domestic proceedings involving the SFO and FCA. Sources say he is "quietly impressive and inspires confidence."

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Band 4

Byrne and Partners LLP

From the Chambers UK guide

Sara Teasdale has a strong record of advising individual clients from the financial services industry facing criminal investigation, as well as related regulatory proceedings. Clients recommend her as an "extremely talented and experienced lawyer who has a comprehensive understanding of the field in which she operates," adding that she has an "impressive ability to quickly understand a complicated situation and identify the relevant points and issues."

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Band 4

Bambos Tsiattalou

Stokoe Partnership Solicitors

From the Chambers UK guide

Bambos Tsiattalou is a former barrister and the founding partner of Stokoe Partnership, with a wide-ranging criminal practice that includes serious fraud. According to clients, he is "an exceptional lawyer" who "instantly fills you with confidence" and "knows every detail of the case."

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Band 4

Bindmans LLP

From the Chambers UK guide

Katie Wheatley has a wide-ranging criminal practice and a growing reputation for her fraud work for clients from the financial services industry. Sources comment that she is "fantastic with clients," with one interviewee saying: "She is incredibly hard-working and thorough."

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Up and Coming

BCL Solicitors LLP

From the Chambers UK guide

The "bright and enthusiastic" Shaul Brazil is noted by commentators for an "urbane, easy-going manner that makes individuals warm to him." He is a qualified barrister with a growing reputation for his work in financial crime, which includes a number of multi-jurisdictional, multi-agency investigations.

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Up and Coming

Stokoe Partnership Solicitors

From the Chambers UK guide

Amjid Jabbar of Stokoe Partnership acts on a variety of cases in fraud and financial crime, with a recent focus on high-value tax fraud. Clients commend him as "a diligent hard worker" who is "always available."

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Up and Coming

Hodge Jones & Allen LLP

From the Chambers UK guide

Kiran Mehta is a criminal solicitor with a growing reputation in fraud and financial crime. Interviewees say he is "very bright and definitely going places," with one source commenting: "He is very hard-working, brilliant at spotting issues and an amazing strategist."

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Up and Coming

WilmerHale

From the Chambers UK guide

Elly Proudlock has a fast-growing reputation for representing individuals facing SFO investigations into offences including corruption and money laundering. Sources describe her as "extremely bright and hard-working," and clients commend her as a "good lawyer with a very analytical mind."

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Associates to watch

Rahman Ravelli Solicitors

From the Chambers UK guide

Neil Williams of Rahman Ravelli Solicitors is a senior associate with a strong record of handling high-stakes cases in fraud and financial crime. According to interviewees, "he mixes a logical and structured analysis with an experienced but creative response," while "his authority over the facts is impressive and his relentless attention to detail is inspiring."

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