Regulatory litigation

Versatile, experienced and talented.  A tenacious, award winning team able to provide the whole range of expertise needed when clients are confronted by regulators.  Our reputation for advising and representing clients in the most complex investigations and enforcement actions in the financial sector, including the FCA and the PRA, is outstanding.  
  • Profile
  • Experience
  • Key contacts
Our regulatory litigation practice has been at the forefront of high profile investigations and enforcement for many years.  It acts for individuals and corporates.  Clients include senior executives as well as retail and investment banks, hedge funds, and professional service firms. The team includes former prosecutors and regulators.

We assist the client from the first call of the regulator, the information gathering and interview processes, making representations to the Regulatory Decisions Committee, and taking cases to the Upper Tribunal and beyond.  Where appropriate, we negotiate settlements and design redress and remediation programmes.  We also act on contested authorisation and approval applications.

Recent instructions have included acting for clients who have been targeted by regulators and prosecutors in the UK and overseas in the global investigations into the manipulation of LIBOR and the FX markets.  These cases exhibit the team's capabilities in both the regulatory and criminal contexts of trader misconduct and in regulatory investigations into systems and senior management failures.

We work closely with colleagues in other specialist areas of the firm, notably funds, regulatory, compliance and employment.

With the increasingly global nature of regulatory litigation, we have well established links with high quality firms in other jurisdictions, as well as our own overseas offices. 

"An excellent firm in the field of regulatory investigations, with unparalleled experience of dealing with the SFO, FCA and other overseas bodies."
The Legal 500 UK 2017


Representing individuals under investigation by the FCA and various US financial regulators for involvement in the manipulation of LIBOR and for the inadequacy of systems and controls to prevent manipulation.  

FX – trading misconduct

Acting in the regulatory investigations by authorities both in the UK and the US of a number of employees of major global investment banks accused of rigging in the G10 FX Spot trading desk.

FX – systems and controls failures

Representing the heads of FX at two global investment banks in an investigation by the FCA into their responsibility for systemic failings on the G10 FX Spot trading desks, leading to large scale fraudulent activity by desk traders.  

Senior management – organisational failings

Defending John Pottage and Matthew Brumsen in attempts by the FSA to penalise them for failing to take reasonable care in organising and controlling the affairs of UBS, following a fraud in the bank's private wealth business.

Fraud – systems failings

Representing one of the largest asset management firms in the City of London in an investigation into the alleged inadequacy of its systems to prevent fraud.


Acting for financial institutions in relation to selling issues concerning retail products and the design of schemes of arrangement to provide redress.

Conduct of business rules

Acting for HSBC in FCA enforcement proceedings for alleged conduct of business rule breaches in its role as depositary to the Arch Cru funds, including participating in a mediation to arrange for investor compensation.

Parliamentary Commission on Banking Standards and the HBOS Review

Acting for Peter Cummings in enforcement proceedings brought against him by the FCA in his role as CEO of the corporate division of HBOS, and subsequently advising him in his evidence to the PCBS and the HBOS Review, including its Maxwellisation process.

Anti-money laundering

Acting for a bank and a hedge fund in relation to failings in their anti-money laundering procedures, drafting new procedures, and representing the MLRO in disciplinary proceedings.

Relations with regulators

Working with two magic circle firms in defending the Prudential and its global CEO in an investigation and proceedings by the FCA into the Prudential's failure to notify the FCA of its intention to acquire AIA.

Judicial review

Challenging the abuse of power by regulators, including setting aside unlawful search warrants and compelled information requirements, and curbing proposed enforcement steps. 


Advising RBS and staff in an internal investigation into allegations that borrowers were inappropriately placed into insolvency and an inquiry conducted under section 166 of the Financial Services and Markets Act 2000. 

Tony Woodcock Partner

T:  +44 20 7809 2349
M:  +44 7825 625 903 Email Tony | Vcard Office:  London

Latest news & insights

17 Jan 2018

From Insights

Investigation and enforcement: the FRC and FCA enter into a Memorandum of Understanding

On 20 December 2017, the FRC and the FCA entered into an MoU. The purpose of the MoU, although not legally binding, is to "assist co-operation and co-ordination" betwe..


16 Jan 2018

From Insights

FCA consults on transition to SM&CR

The FCA notes that "individuals at Limited Scope Firms and Core Firms will be automatically converted wherever possible, with no action required by firms".


30 Nov 2017

From Insights

FCA puts compliance functions on notice

On 23 November 2017, the FCA published the results of its research into compliance functions in wholesale banks.


09 Nov 2017

From News

Stephenson Harwood achieves successful stay in Tom Hayes FCA ban proceedings

Law firm Stephenson Harwood LLP has advised former trader Tom Hayes in successfully halting a Financial Conduct Authority (FCA) ban.


31 Oct 2017

From Insights

Important changes to the SAR regime

On 31 October 2017 Sections 10 – 12 of the Criminal Finances Act 2017 (the "Act") will enter into force, making the most significant changes to the money laundering re..


02 Aug 2017

From Insights

Regime change: FCA consults on extending the Senior Managers and Certification Regime to all FCA firms

The way in which the FCA regulates individuals in financial services is changing. On 26 July 2017 the FCA published a consultation on extending the Senior Managers and..


26 Jul 2017

From Insights

US LIBOR case deals a blow to cross-border assistance and clarifies the use of compelled evidence

A US Appeals court has reversed the convictions of two ex-Rabobank employees in connection with their alleged roles in the manipulation of LIBOR.


19 Jun 2017

From News

Stephenson Harwood named 'Law firm of the Year' by Operational Risk

Stephenson Harwood LLP has been named 'Law firm of the Year' at the Operational Risk Awards 2017, for the second year running.


11 May 2017

From Insights

Criminal Finances Act 2017: Revolution not evolution

Sneaking onto the statute books ahead of June's General Election, the Criminal Finances Act 2017 (the "Act") received Royal Assent on 27 April 2017. It represents one ..


29 Mar 2017

From Insights

FCA v Macris – Supreme Court gives judgment on "third party rights"

On Wednesday 22 March the Supreme Court handed down its much-anticipated judgment in Financial Conduct Authority v Macris [2017] UKSC 19.


27 Jan 2017

From Insights

Rolls-Royce: Deferred Prosecution Agreement No. 3

On 17 January the Serious Fraud Office ("SFO") announced that it had entered into a deferred prosecution agreement ("DPA") with Rolls-Royce PLC.


17 Jan 2017

From Insights

2017 - Preparing for the extension of the New Accountability Regime

The SM&CR introduced for banks, building societies, PRA-designated investment firms and credit unions in March last year – is due to be extended to the whole financial..


14 Oct 2016

From Insights

FCA cracks down again on AML systems and controls

On 12 October 2016 the FCA issued a Final Notice against Sonali Bank (UK) Limited. The Notice is a timely reminder for authorised firms that weak financial crime contr..


19 Aug 2016

From Insights

HMRC raises the stakes for tax avoidance enablers

On 17 August, HMRC launched a consultation setting out proposals to impose punitive sanctions on those who design, promote and market tax avoidance schemes. We examine..


15 Jun 2016

From News

Stephenson Harwood named ‘Law firm of the Year’ by Operational Risk

Stephenson Harwood LLP was named ‘Law firm of the Year’ by Operational Risk, at an awards ceremony held in London on June 14.


03 May 2016

From Insights

FCA consults on proposed amendments to enforcement procedures

The FCA and the PRA have together opened a consultation on a number of proposed changes to the current enforcement decision-making process and consequent proposed amen..


© Stephenson Harwood LLP 2016. Any reference to Stephenson Harwood in this document means Stephenson Harwood LLP and/or its affiliated undertakings. Any reference to a partner is used to refer to a member of Stephenson Harwood LLP.