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
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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. 

"If you’re facing an FCA investigation, you’d be mad not to have them at the top of your list."

The Legal 500 UK 2021


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.  

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.

Sean Jeffrey Partner

T:  +44 20 7809 2034
M:  +44 7584 235 262 Email Sean | Vcard Office:  London


Justin McClelland Partner

T:  +44 20 7809 2127
M:  Email Justin | Vcard Office:  London

Latest news & insights

16 Feb 2021

From Insights

The SFO and KBR: UK Supreme Court limits extraterritorial effect of SFO powers

In R (on the application of KBR, Inc) (Appellant) v Director of the Serious Fraud Office (Respondent) [2021] UKSC 2 the Supreme Court held that the Serious Fraud Offic..


15 Feb 2021

From Insights

Post-Brexit UK / EU extradition arrangements: business as usual?

On 24 December 2020, the UK and the EU agreed the terms of the Trade and Cooperation Agreement (the “TCA”).


11 Feb 2021

From Insights

Money laundering risks in the gambling sector

Recent developments and enforcement action taken within the gambling sector have highlighted the need for operators to carry out a robust assessment of their money lau..


21 Oct 2020

From Insights

Looking ahead: Proposed changes to the Modern Slavery Act 2015

On 22 September 2020, the government published its response to a public consultation on transparency in supply chains.


10 Aug 2020

From Insights

The Boohoo scandal: A reminder of Modern Slavery Act 2015 obligations

The recent undercover investigation by The Sunday Times into poor pay and working conditions at a supplier of the fast-fashion retail brand Boohoo is a timely reminder..


21 Jul 2020

From Insights

Disclosure of risk/compliance documents and minutes: involvement of lawyer not enough for privilege

In A v B and the FRC [2020] EWHC 1492 , a company which believed that internal governance and compliance documents (including a risk register and board minutes) had be..


23 Jun 2020

From Insights

HMRC and the Covid-19 furlough scheme: New civil enforcement powers emerge, but prosecutions remain in prospect

In response to the Covid-19 pandemic the UK Government has committed billions of pounds to preserving livelihoods and jobs via the Self-Employment Income Support Schem..


07 Apr 2020

From Insights

Tony Woodcock features in Lexology Learn Hub’s latest video series on anti-money laundering

Head of the firm’s regulatory litigation and corporate crime practice Tony Woodcock, features in the latest Lexology Learn series, which focuses on anti-money launderi..


05 Aug 2019

From Insights

FCA publishes final rules confirming amendments to the SMCR

On 26 July 2019, in Policy Statement 19/20 the FCA published its final rules confirming amendments made to the Senior Managers and Certification Regime (“SMCR”), toget..


09 May 2019

From Insights

SM&CR Extension: issues for solo-regulated firms to consider as implementation date approaches

From 9 December 2019 47,000 FCA solo-regulated firms will become subject to the Senior Managers and Certification Regime ("SM&CR").


25 Mar 2019

From Insights

SFC imposes largest ever fines for sponsor failures

On 14 March 2019, Hong Kong’s securities regulator, the Securities and Futures Commission (the “SFC”) imposed its largest ever fines for sponsor failures in IPOs. All ..


04 Feb 2019

From Insights

Heads of Legal not required to be Senior Managers

Firms, in-house lawyers and the legal profession generally will be relieved that the Financial Conduct Authority ("FCA") has decided to exclude firms' Heads of Legal f..


20 Dec 2018

From Insights

Update on litigation privilege

2018 has seen a flurry of cases concerning the ambit of legal professional privilege, in particular the scope of litigation privilege, including the high profile Court..


22 Oct 2018

From Insights

Developments and trends in FCA enforcement (webcast 2018)

Ellen Gallagher takes a look at the trends emerging from FCA enforcement action against firms and individuals over the last year and looks forward to consider what the..


25 Sep 2018

From Insights

Disclosure of privileged documents ordered in regulatory investigation: ground-breaking High Court decision

In what "is believed to be the first application of its type to have reached the courts", Arnold J granted an order requiring Sports Direct International PLC to disclo..


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