Jeremy’s primary areas of practice include business crime, sanctions, regulation and commercial litigation – in particular financial crime, investigation and regulation, in both the public and private sectors. More widely, he acts in commercial and regulatory cases involving cryptoassets and data protection/privacy issues. He has a growing public law practice, growing out of his work on sanctions/business crime, information law and criminal justice.
He is well-suited to advise and represent clients with complex commercial disputes, particularly those involving financial services and regulators. His commercial acumen arises in part from working in senior banking roles in Standard Chartered Bank and Bank of Montreal for seven years prior to becoming a barrister. During that time he led investigations and compliance programmes at a global level, resolving commercial and regulatory problems involving financial crime issues from corruption and fraud to sanctions and money laundering, as well as broader regulatory concerns.
As a former lead investigator for a London-based international bank, he is also skilled in managing complex and delicate enquiries and investigations, while his experience in handling both commercial and employment litigation enables him effectively to mitigate the risks to which such an enquiry can give rise.
In 2023, Jeremy was appointed to the Attorney-General’s C Panel of junior counsel to the Crown.
Before his time in banking (during which he served, among other roles, as StanChart’s deputy global head of anti-corruption), Jeremy was an intelligence and investigations specialist at the Financial Services Authority, latterly serving as its deputy MLRO. Before that, he was a reporter for the BBC, specializing in investigating financial crime.
Jeremy is public access qualified and accepts instructions directly from members of the public. He is also a qualified mediator: a skill which not only enables him to assist as a neutral arbiter in disputes, but to represent clients effectively in commercial mediations.
For almost two decades before coming to the Bar, Jeremy specialised in dealing with financial crime issues, intelligence and investigations. He is therefore a specialist in assisting clients get to the bottom of complex investigations and in dealing with allegations of fraud, bribery and corruption, and money laundering. His long experience in bribery and corruption matters led to his authoring the first chapter in Lissack and Horlick on Bribery and Corruption, the third edition of which was published in 2020.
Jeremy also has wide experience of contempt of court. He has appeared twice, unled, in the Court of Appeal on contempt matters: one of these cases, Westrop v Harrath [2023] EWCA Civ 1566, is now cited in the White Book 2024 as setting the ground rules for findings of contempt arising from Part 71 of the CPR.
Much of his work involves dealing with the proceeds of crime and asset recovery, as well as customs seizures. He has wide experience of POCA, acting both for law enforcement authorities such as HM Revenue & Customs and against them. For HMRC, he acts currently in a number of frozen funds and civil recovery investigations, involving predicate criminality such as Covid and MTIC fraud; for respondents, he has frequently sought and achieved release of both goods and funds, as well as defeating applications for costs and compensation protection made by law enforcement. In allied matters, he is currently representing a government department in multi-million pound civil proceedings in the High Court involving customs issues and the Misuse of Drugs Act 1971.
Jeremy’s experience in internal investigations enables him to both plan and run enquiries into misconduct or suspected criminality, and to advise on how to mitigate the legal risks which can arise from such enquiries. He can be engaged to assist with investigations on a direct access basis if desired.
More widely, he has experience of matters relating to the law of international and multilateral organisations.
Among recent instructions:
Led by Oliver Powell KC, advising an Emirati investment house in relation to a multi-million euro fraud: pursuing novel applications under POCA in the Administrative Court and successfully achieving Norwich Pharmacal relief against a UK high street bank to trace the stolen funds.
Defending a government department in a multi-million pound High Court claim concerning the import of cannabis flowers, in which the claimant is seeking – in effect – to redefine the prohibitions in the Misuse of Drugs Act 1971.
Led by Oliver Powell KC, advising a UK law enforcement agency in connection with a multijurisdictional fraud investigation focusing on a British Overseas Territory. Including advice on charging, evidence, interviewing and jurisdictional issues, and the drafting and negotiation of memoranda of understanding and international letters of request.
Advising and representing HMRC in various courts and tribunals in relation to POCA and the MLR, including a large Covid fraud involving freezing orders over both bank accounts and multiple real properties, and several MTIC frauds; and defending HMRC against multiple data protection allegations.
Advising and representing multiple clients faced with frozen funds and listed assets investigations. In one case, led by Robert Rhodes KC, an agreement to forfeit listed assets led to the discontinuance of the investigation of criminal charges which could have led to lengthy prison sentences. In several others, forfeiture has been successfully resisted.
Appearing unled in Westrop v Harrath [2023] EWCA Civ 1566, to persuade the Court of Appeal to set aside a contempt committal following the High Court’s failure properly to follow the procedure set out in CPR Part 71.
Achieving the withdrawal of an unmeritorious contempt application brought in the context of long-running commercial litigation.
Led by Helen Pugh, defending a client accused of lying to the Court in a five-day civil and criminal contempt trial before the High Court.
Avoiding immediate committal in a High Court contempt action, despite the contemnor having repeated an earlier contempt.
Acted for the Solicitors’ Regulation Authority in multiple proceedings before the Solicitors’ Disciplinary Tribunal (both Rule 12 referrals and appeals against SRA sanctions), as well as advising on a number of tribunal referrals concerning solicitors’ obligations under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017.
Led by Ben Compton KC, defending a London bar and restaurant chain accused of major health and safety violations; and assisting Ben in advising multiple clients on other health and safety matters.
Advising a government department on cross-border evidence issues in the context of a long-running fraud investigation.
Both prosecuting and defending clients in the Crown Court and magistrates’ courts in relation to health and safety offences.
Acting as external counsel to the Post Office’s Assurance and Complex Investigations team, as they investigated allegations of discrimination within the Horizon prosecutions.
Advising and representing the HSE in seeking the strike-out of an unmeritorious challenge to health and safety enforcement.
Led by Alex Haines, representing a staff member of the International Monetary Fund in a dispute with IMF management.
Led by Oliver Powell, advising the MCA on the implementation of the Merchant Shipping (Watercraft) Order 2023, including helping the MCA liaise with partner agencies and training more than 100 MCA staff on how the new rules affect personal watercraft and their owners and users.
Advising on and representing the MCA in prosecutions under the 1993 Merchant Shipping (Registration) Regulations in the crown courts.
Acting for a pensions trustee in the case of R v Luckhurst, negotiating an agreement with the defendant over the use of funds restrained under PoCA.
Representing numerous importers of nitrous oxide whose goods have been seized on entry into the UK, achieving the return of the property without a condemnation hearing for several clients, defeating an application for an s144 certificate of reasonableness, and appearing in the magistrates’ and crown courts in relation to the Psychoactive Substances Act 2016.
Assisting (along with several other counsel) in a major sanctions and money-laundering investigation undertaken by a Crown Dependency.
A significant part of Jeremy’s business crime practice is in advising on matters relating to sanctions and export controls issues in the UK, US, EU and certain Crown Dependencies.
This advice has been for individuals, corporates, and governmental bodies, and covers a range of issues from the permissibility of corporate and commercial proposals, to assistance with the interplay of sanctions regimes and financial regulatory issues, to advising on the applicability of sanctions to private client matters.
In particular, since January 2025 Jeremy has acted as counsel to the Office of Trade Sanctions Implementation (OTSI) within the Department for Business, Innovation, Science and Trade, advising on licensing and enforcement matters and on the implementation of the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (“TASSCER”). He has also advised the Office of Financial Sanctions Implementation (OFSI) within HM Treasury.
In the private sector, Jeremy is frequently called upon to advise on both sanctions and export controls issues. He has a particular knowledge of the interplay between trade sanctions and export controls, but also deep experience of how sanctions and insolvency interact, of services restrictions, and of the intricacies of financial sanctions and designation procedures.
Jeremy’s work has given him a detailed understanding of the UK sanctions regimes created under the Sanctions and Anti-Money Laundering Act 2018, including but not limited to the Russia (Sanctions) (EU Exit) Regulations 2019; the “EU Blocking Regulation” (Council Regulation (EC) 2271/96); and the UK’s export control architecture, in particular the Export Control Act 2002, the Export Control Order 2008, and the UK Dual-Use Regulation.
Jeremy’s work to date has included:
Jeremy’s work to date has included:
Jeremy’s instructions in financial services, regulation and crime often have public law implications. To that end, he frequently acts in public law matters, both led and unled: both in resisting applications for judicial review, and on matters relating to parole and prisons. He has advised other clients in the financial services as to potential public law implications of their decisions and strategies.
As a member of the Attorney-General’s panel of counsel (the C Panel), Jeremy frequently acts for public bodies both in court and on an advisory capacity, including (for instance) advising on cross-border regulation of professionals in the context of mutual recognition of qualifications with Switzerland. In court, Jeremy has specialised in acting for government bodies in relation to data protection and information law matters.
Among other matters, he has:
Led by Gemma White KC of Blackstone Chambers, drafted Reasons in only the third application ever to be made by the Secretary of State for Justice (under new powers) to refer to the High Court Parole Board decisions to release prisoners serving life sentences.
Represented West Midlands Police in an application for judicial review arising from stops of abnormal load vehicles.
Led by John McKendrick KC (now Mr Justice McKendrick), represented a UK trade body in its application for judicial review of the FCA’s rules on claims management company fees.
Successfully represented the Secretary of State for Justice in several habeas corpus proceedings, once after being instructed at less than an hour’s notice.
Represented the Secretary of State for Justice in multiple parole-related proceedings, including resisting applications for judicial review of decisions to decline Parole Board recommendations for transfer of prisoners to open conditions.
Provided public law advice to OTSI in relation to sanctions and export controls on an ongoing basis since January 2025, as well as to ECJU and OFSI on several occasions during that period.
Building on his experience with investigations, regulatory matters and public law, Jeremy has a growing practice in the law of international organisations as it relates to its staff and employee relationships. This includes representing both staff who are accused of misconduct or raise grievances with their employers, and advising international organisations both on procedural matters and rules and on investigations.
His instructions in this area include:
• Led by Alex Haines, representing a senior staffer at the International Monetary Fund (IMF) in an application to the International Monetary Fund Administrative Tribunal (IMFAT);
• Investigating allegations of misconduct and harassment made against two senior members of staff at a Europe-based international organisation, including advice to the organisation as to the jurisprudence of the International Labour Organization Administrative Tribunal (ILOAT).
Jeremy has advised and represented regulators including the CQC in their oversight of regulated entities. He has also assisted clients in their dealings with the Financial Conduct Authority, the Gambling Commission, the Serious Fraud Office, the Maritime and Coastguard Agency and the Health and Safety Executive. He has represented the Metropolitan Police Service in misconduct and performance hearings, and advised the MPS in relation to data protection and other matters.
He acts in cases where there are data protection and privacy/confidentiality issues. Among recent instructions:
Successfully defended HM Land Registry in the First-Tier Tribunal in a Freedom of Information Act 2000 (FOIA) appeal which – if successful – could have forced it to provide for free large amounts of information for which statute currently allows it to charge a fee.
Defending the Department for Business, Information, Science and Trade in a FOIA appeal involving national security issues.
Advised the Department for Health and Social Care on sensitive data protection and FOIA matters arising from the closure of the Tavistock and Portman NHS Trust, and the deaths of young trans people.
Led by Ed Morgan KC, advised on and investigated potential data breaches against an NHS services provider by a former employee, including successfully advising on dealings with its regulators.
Defended HMRC successfully in multiple data protection matters.
Acted successfully for a major UK mobile phone carrier in one of the first UK cases to consider data protection and privacy liability for SIM-swapping fraud.
Advised and represented NHS trusts in matters dealing with complex data protection and privacy cases, on several occasions resulting in proceedings being either dropped or settled advantageously.
Advised and represented claimants seeking compensation for breaches by both public and private organisations, including helping a client win significant compensation from a public authority which unlawfully disseminated confidential information about sexual abuse.
Advised corporate clients on the handling of law enforcement data requests.
Acted for both regulators and respondents in disciplinary hearings brought by the Solicitors Regulation Authority and the Bar Standards Board.
Successfully represented the FCA and government departments in the First-Tier Tribunal in data protection and freedom of information cases.
Achieved strike-out or summary judgment in a number of data protection and information law claims brought against government departments.
Having spent more than a decade in banking and regulation, Jeremy has particular expertise in dealing with financial services matters. He has provided advice to, and been seconded to, the Financial Conduct Authority, working both with its General Counsel’s Division and with Supervision and Enforcement; and the Payment Systems Regulator. He also spent a year supporting the Independent Third Party addressing complaints from small business customers of RBS’s Global Restructuring Group. His regulatory experience includes work on the developing area of investments in, and regulation of, medicinal cannabis firms. He has advised and acted for clients in several crypto-related matters.
With Henry Reid and others, Jeremy was part of a team during early 2024 which drafted the Financial Services Lawyers’ Association response to the FCA’s plans to name and shame the subjects of enforcement investigations.
Recent instructions include:
Advising the Payment Systems Regulator on long-term regulatory projects, including account-to-account payments within Open Banking, and amendments to the FCA Handbook.
Led by Oliver Powell KC, advising on a group action against a wealth management company in relation to the FCA’s Appointed Representative rules.
Advising a senior banking executive on the recovery of large sums lost in CfD trading.
Led by John McKendrick KC, representing a trade body seeking judicial review of new FCA rules governing claims management companies.
Led by Oliver Powell KC, representing the CEO of a Lloyd’s of London insurer in an appeal against a regulatory sanction imposed by the market.
Led by Justina Stewart, representing an individual client in a seven-figure dispute with a High Street bank.
Advising a trade union on the FCA’s non-financial misconduct rules.
Advising a law firm on whether proposals relating to legal funding would fall within the FCA’s regulatory perimeter.
Successfully defeating an attempt by a claimant to extend the Quincecare duty to a receiving bank.
Advising a US investment group on its application for FCA authorisation, including issues under the Senior Managers and Conduct Regime.
Advising a wealth management firm on the resignation (following conflicts of interest) of a founder and director.
Advising UK and US clients on perimeter issues including cryptoassets, litigation funding, contracts for difference, and insurance.
Advising several clients on FOS claims, both complainant and respondent, involving six-figure losses and issues ranging from COBS and BCOBS to the Quincecare duty and Covid business interruption insurance claims.
Representing an individual in a six-figure dispute concerning an alleged failure by a financial adviser to follow instructions and breach of trust.
Successfully appealing a judgment against an authorised firm which risked leaving it liable to pay significant sums to its former appointed representatives.
Advising a law firm on the application of CASS, claims management and insurance regulation.
Advising UK and overseas clients on the use of blockchain technologies for regulatory purposes.
Jeremy has a broad commercial practice, appearing in court (both at the interim and final stages) and advising on a variety of claims involving contract issues, restitution, company law and insolvency. In relation to the latter, he has recently advised on jurisdictional issues.
Jeremy acts in matters relating to cryptoassets and smart contracts. Within these areas, Jeremy has presented webinars on the financial crime aspects of cryptoassets, and been part of the legal team on disputes involving the question of whether (and if so, on what basis) cryptoassets can be considered property.
Recent instructions include:
Led by James Leonard KC, defending a client facing multi-million pound civil fraud allegations.
Led by Oliver Powell KC, advising and drafting pleadings for an overseas energy company in the Admiralty Court, in litigation valued at some 30 million euro.
Led by Justina Stewart and as sole counsel, advising clients and litigation funders on potential crypto-related fraud claims.
Led by Oliver Powell KC, advising on a group action against a wealth management company in relation to the FCA’s Appointed Representative rules.
Led by Oliver Powell KC, advising a client on options for recovery of harm to property arising from misconduct on the part of a water undertaker.
Advising a number of clients in relation to potential section 994 applications – both bringing them and defending against them.
Representing professional firms – one accountants, one law firm – in disputes with technology services providers (one unled, one led by Edward Morgan KC). The subject matter included the after-effects of in one case a ransomware attack (settled at mediation), and in the other comprehensive IT failure on the part of the provider.
Advising insolvency practitioners on (among other things) assignment and novation of contractual rights and contractual liens in the context of a major shipping insolvency.
Advising a manufacturer on resolving the failure of a multi-million pound piece of equipment in the context of a commercial leasing arrangement.
Strategic advice to a technology firm seeking to enforce restrictive covenants following the departure of key senior staff; and advising it on potential civil fraud litigation and private prosecution.
Advising a law firm on issues arising from its LLP agreement in relation to a planned merger.
Advising the partners of a law firm in relation to a threatened bankruptcy petition.
Achieving the dismissal of a bankruptcy petition on jurisdictional grounds (under sections 265-268 of the Insolvency Act 1986).
Advising the board of a wealth management firm in relation to the misconduct and conflicts of interest of one of the directors.
Representing a technology firm in an ongoing dispute with its investors.
Advice and representation in a dispute between joint venture partners, including issues of both breach of contract and directors’ duties.
Advice to several clients on cross-border jurisdiction and choice of law cases, including advice on potential civil fraud and agency claims.
Advice and drafting of particulars for the claimant in a contract dispute, which led to concession and settlement (including costs) on the part of the prospective defendant.
Advising and drafting pleadings in a High Court claim based on agency and unjust enrichment.
Advising and representing clients in company and insolvency matters.
Securing summary judgment for lenders in a number of actions against defaulting borrowers, including striking out civil fraud allegations.
Jeremy’s background in risk and compliance has led him into a thriving practice in health and safety, where his knowledge of the realities and practicalities of risk management – coupled with his experience of large organisations and financial crime – has been of use to regulators, prosecutors and defendants alike.
Jeremy has acted frequently for the Maritime and Coastguard Agency (MCA), both led by Oliver Powell and as sole counsel, in a number of matters: investigations, advice, liaison with partner agencies and prosecutions.
He also prosecutes for water companies, advises and represents the HSE, and defends against local authorities and others.
Led first by Ben Compton KC and now by Oliver Powell KC, advising on and defending a demolition company facing potential prosecution in relation to the collapse of Didcot Power Station in 2016.
Led by Ben Compton KC, defending a London bar and restaurant chain accused of major health and safety violations; and assisting Ben in advising multiple clients on other health and safety matters.
Represented several fishing firms and vessels in prosecutions brought by the Maritime and Coastguard Agency, securing significant reductions in anticipated fines.
Represented a Scottish provider of maritime training in an inquiry following the withdrawal of its licence by the Maritime and Coastguard Agency.
Achieving the acquittal, following a three-year investigation, of a Transport Manager facing an indictment for aiding and abetting the falsification of tachograph records, by persuading the prosecution to offer no evidence before their case was even opened.
Representing the management company of a residential development facing huge post-Grenfell redevelopment expenses, securing a judgment which allowed it to spend scarce resources on upgrading its fire alarm system rather than on a waking watch.
Advising on and representing the MCA in prosecutions under the 1993 Merchant Shipping (Registration) Regulations in the crown courts.
Led by Oliver Powell KC, advising the MCA on the implementation of the Merchant Shipping (Watercraft) Order 2023, including helping the MCA liaise with partner agencies and training more than 100 MCA staff on how the new rules affect personal watercraft and their owners and users.
Led by Oliver Powell KC, advising a UK law enforcement agency in connection with a multijurisdictional fraud investigation focusing on a British Overseas Territory. Including advice on charging, evidence, interviewing and jurisdictional issues, and the drafting and negotiation of memoranda of understanding and international letters of request.
Advising several international corporates on the effects of health and safety legislation on their businesses – and the potential of individual liability for their senior executives.
Advising and representing the HSE in seeking the strike-out of an unmeritorious challenge to health and safety enforcement.
Both prosecuting and defending clients in the Crown Court and magistrates’ courts in relation to health and safety offences.
Jeremy’s in-house commercial and investigative experience led to significant involvement with employment matters even before he was called to the Bar. He is often instructed by both claimants and defendants in complex employment matters, including whistleblowing, discrimination, TUPE and unfair dismissal disputes. He has assisted counsel including David Grant KC in appeals before the Employment Appeal Tribunal. He is co-author of the 8th edition of the Employment Law Handbook, edited by Daniel Barnett and published in November 2020.
His expertise in investigations has enabled him to undertake complex investigations into allegations of misconduct made between senior individuals at a leading UK university, as well as undertaking investigations into alleged harassment and misconduct among senior officers of a Europe-based international organisation.
He now mainly undertakes employment matters where they intersect with his other specialisms: particularly business crime and regulated financial services.
To find out more, contact Lexie Johnson on + 44 (0) 207 427 0801 or Andy Hunter on +44 (0)20 7427 4905 for a confidential discussion.
Read Jeremy’s Privacy Policy.
