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. 

"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

08 Sep 2023

From Insights

The FCA's PEP talk…..

This week, we have seen the Financial Conduct Authority ("FCA") publish the terms of reference in relation to its Review of the treatment of UK-domestic politically ex..


16 Aug 2023

From Insights

When may an individual be liable to make restitution for regulatory breaches by their firm? The meaning of "knowingly concerned" revisited

The Financial Conduct Authority has the power to seek court-ordered restitution orders against firms, and individual "knowingly concerned" defendants in respect of reg..


11 Aug 2023

From News

New FCA "Dear CEO letter" sets out wide-ranging expectations and requirements in relation to Principal Trading Firms

On 4 August 2023, the Financial Conduct Authority ("FCA") sent a "Dear CEO letter" setting out their supervisory strategy for "Principal Trading Firms" ("PTFs"). The ..


10 Jul 2023

From Insights

FCA launches consultation on a proposed framework for establishing a consolidated tape in the UK

As part of a series of measures announced on 5 July 2023, the FCA published a Consultation Paper in relation to their proposed framework for establishing a "Consolidat..


26 Jun 2023

From Insights

The Bank of England/PRA’s consultation on its approach to enforcement

On 21 June 2023, the BoE/PRA)'s Head of Enforcement and Litigation, Oliver Dearie, gave a speech the Financial Services Lawyers Association explaining the rationale be..


13 Jun 2023

From Insights

The UK Financial Conduct Authority's new rules in relation to the regulation of financial promotions in respect of cryptoassets

The UK Financial Conduct Authority ("FCA") has published its near-final rules in relation to the regulation of financial promotions in respect of cryptoassets.


08 Jun 2023

From Insights

First speech by new FCA Head of Enforcement – key takeaways

Last week, Therese Chambers made her first speech as newly appointed Joint Executive Director of Enforcement and Market Oversight at the FCA.


05 Jun 2023

From Insights

Data Protection update - May 2023

Welcome to the Stephenson Harwood Data Protection bulletin, covering the key developments in data protection law from March 2023.


24 May 2023

From Insights

The Financial Services and Markets Bill – a "bonfire" of retained EU financial services law, or something less?

The Government has recently announced that it had dropped plans to get rid of European laws by the end of 2023.


15 May 2023

From Insights

Blowing the whistle to the FCA – the regulator's assessment of its processes for handling reports yields "disappointing" results

On 4 May 2023, the FCA published a report setting out the findings of its own qualitative assessment in relation to its handling whistleblowers who directly report to ..


04 May 2023

From Insights

Data Protection update - April 2023

Welcome to the Stephenson Harwood Data Protection bulletin, covering the key developments in data protection law from March 2023.


02 May 2023

From Insights

The FCA's latest Market Watch 73

The FCA's latest edition of Market Watch focusses on their recent market abuse peer review in relation to firms that offer CFDs and spread bets ("CFD providers").


19 Apr 2023

From Insights

First SMCR enforcement decision for failure to take "reasonable steps"

On 13 April 2023, the Prudential Regulation Authority published a Final Notice in relation to Mr. Carlos Abarca imposing a financial penalty of £81,620


13 Apr 2023

From Insights

New UK "failure to prevent fraud" offence

On 11 April 2023, the UK Government announced that it intends to create a new and broad corporate offence of failing to prevent fraud.


11 Apr 2023

From Insights

Reform of SMCR: UK Government and regulators commence Review

In December 2022, the Chancellor of the Exchequer announced the Edinburgh Reforms, "to drive growth and competitiveness in the financial services sector."


03 Mar 2023

From Insights

Data Protection update – February 2023

Welcome to the Stephenson Harwood Data Protection bulletin, covering the key developments in data protection law from February 2023.


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