Business Crime and Sanctions

We advise corporates, financial institutions and individuals on all aspects of business crime, including regulatory enforcement and financial sanctions.

Our team is recognised for its commercial focus and extensive international experience, and is regularly entrusted with clients’ most sensitive and business-critical situations.

We regularly represent clients facing investigations by the UK’s Serious Fraud Office (SFO), Financial Conduct Authority (FCA), HM Revenue & Customs (HMRC), Office of Financial Sanctions Implementation (OFSI), and other domestic and international regulators and enforcement bodies. 

Our work includes:

• fraud, bribery, corruption, money laundering, market abuse, insider dealing and facilitation of tax evasion;
• self-reporting processes and managing regulator engagement;
• compelled and voluntary interviews and criminal defence proceedings;
• internal investigations triggered by audits, whistleblowing or third-party claims;
• Unexplained Wealth Orders and Account Freezing Orders;
• cross-border parallel proceedings, extradition or INTERPOL red notices; and
• advising on UK National Security Act 2023 and Foreign Influence Registration Scheme.

We help clients navigate the increasingly complex global sanctions regimes, including the UK, EU and US frameworks.

Our team advises on:

• the interpretation and application of financial sanctions laws;
• UK reporting obligations and engagement with OFSI;
• obtaining licences from UK and overseas sanctions authorities;
• internal investigations following suspected sanctions breaches;
• assessing sanctions risks, reviewing counterparties and providing training; and
• managing conflicts between overlapping or contradictory sanctions regimes.

We design practical policies, risk assessments and tailored training for in-house teams.

We regularly work alongside our colleagues in our Corporate, Tax and Private Client practices to provide joined-up advice on transactions, governance, disclosure and enforcement risks.

Whether we are handling a complex SFO investigation, guiding a whistleblower through enforcement action, or helping a client respond to a fast-moving global issue, our focus is always on protecting our clients’ interests and reputations. 

Work highlights include advising:

• a large corporate who was raided by the SFO following a multi-jurisdictional investigation into fraudulent contracts;
• a corporate in relation to a bribery issue including assisting with a self-report to the SFO and US Department of Justice;
• an individual subject to a high-profile INTERPOL Red Notice before the INTERPOL CCF in Lyon;
• in relation to an internal investigation into financial irregularities at an AIM listed company and on relative action following its suspension of shares due to financial irregularities;
• multiple clients in relation to the interpretation and application of financial sanctions; and
• on obtaining sanctions licences from the UK Government on behalf of a large European financial institution, and on the application of those licences in the course of business.