Our team is able to support you in dealing with the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), National Crime Agency (NCA), Serious Fraud Office (SFO), as well as other regulators regarding compliance related matters.
Financial institutions
Our experience includes but is not limited to:
- advising a large international Bank on anti-money laundering compliance across 22 jurisdictions and the extent to which its global anti-money laundering (AML) policy was fit for purpose in each of the locations
- advising a large retail bank in connection with aspects of a wide-ranging AML change programme (across 19 jurisdictions)
- advising a foreign bank in response to an FCA visit during which significant issues were identified with its AML systems and processes. The work included advising on a VREQ, governance structures, undertaking a gap analysis, introducing a three lines of defence model, drafting policies and procedures and assisting with the remediation of customer files
- representing a foreign bank in FCA enforcement proceedings relating to failings in AML policies and procedures and assisting with file remediation exercise including designing the review methodology
Individuals
Our experience includes but is not limited to:
- representing senior individuals (CEO and MLRO) in FCA enforcement proceedings for alleged AML failings and other regulatory breaches
- acting for over 60 individuals in relation to an investigation, by the FCA, into alleged anti-money laundering breaches
- representing individuals in connection with various benchmark investigations (Libor, FX and others)
- conducting an internal investigation into allegations of financial impropriety against the Chief Executive of a well-known financial institution
Payment services
Our experience includes but is not limited to:
- advising a payment services firm on its anti-money laundering systems and controls, following an FCA visit, and advising on a subsequent VREQ, risk assessments and customer on-boarding procedures
Litigation
Our experience includes but is not limited to:
- acting for the Bank in Squirrel Ltd v Natwest which was the first reported case under POCA dealing with the conflict between a Bank and a customer when an account is frozen because of suspicions of money laundering
- acting for the Bank in K limited v National Westminster Bank which was the first case where the AML provisions under POCA went to the Court of Appeal
- acting for the bank in the seminal case of Jayesh Shah & Another v HSBC Private Bank in a US$300 million claim brought by two former customers
- successfully representing the Bank and an individual in Jeremy Stone and Jeremy Stone consultants v National Westminster Bank and Paul Aplin where the Bank was accused of being knowingly involved in a Ponzi scheme
- acting for the Bank in N v The Royal Bank of Scotland PLC and in NCA v N and The Royal Bank of Scotland PLC
