Sophie specialises in business crime, professional regulation and sanctions.
Sophie is ranked as a Leading Junior in four practice areas by the Legal 500: (1) Business and Regulatory Crime (Including Global Investigations); (2) Fraud; (3) POCA and Asset Forfeiture; (4) Professional Discipline and Regulatory Law.
Her practice areas include: business crime including investigations; sanctions and export control; civil fraud; asset forfeiture; financial regulation and compliance; health and safety; and regulatory & disciplinary proceedings including international institutions.
Sophie is appointed to the Attorney General’s Panel of Junior Counsel to the Crown and the SFO’s International POCA panel.
She co-authored the chapter on Economic Sanctions for Smith, Owen, and Bodnar on Asset Recovery (Criminal Confiscation and Civil Recovery), OUP, and co-authored the chapter of the Bribery Act 2010 to the 3rd edition of Lissack and Horlick on Bribery (LexisNexis) the leading work on bribery and corruption offences, and is co-authoring the chapters on Sanctions and MBD’s & their debarment systems in the revised edition, due 2025.
Recent work includes:
Sophie is an experienced litigator and court advocate, having appeared in significant jury trials concerning, inter alia, corporate bribery and corruption, money laundering and banking, insurance and mortgage frauds. She is often engaged to advise on matters pre-charge in addition to her court practice acting on behalf of prosecuting authorities (SFO, FCA, NCA, TPR, MCA) and defendants in the crown and appellate courts.
Internationally, Sophie has acted in proceedings brought against civil servants by international organisations including the European Bank for Reconstruction and Development (EBRD), International Monetary Fund (IMF), International Fund for Agricultural Development (IFAD), UN Assistance Mission in Somalia (UNSOM) and the African Union Commission (AUC).
In domestic regulatory proceedings, Sophie appears regularly before the GMC, GDC, SRA, NMC, GPhC and HCPC, often defending individuals against the most serious allegations of professional misconduct and negligent care as well as acting for both prosecuting authorities and defendants in health and safety proceeding.
An experienced sanctions practitioner, Sophie’s practice encompasses (i) sanctions issues in commercial litigation, trust administration and international arbitration; (ii) civil, criminal and regulatory enforcement, with particular experience in US secondary sanctions and EU Blocking statutes (iii) bringing or defending administrative law challenges against FCDO listing decisions and HMT (OFSI) decisions that involve licences; (iv) export control advice and investigations into alleged breaches; and (v) advisory work, particularly in relation to UK and EU financial sanctions compliance.
Sophie co-authored the chapter on Economic Sanctions for Smith, Owen, and Bodnar on Asset Recovery (Criminal Confiscation and Civil Recovery), OUP, and co-authored the chapter on the Bribery Act 2010 for the 3rd edition of Lissack and Horlick on Bribery (LexisNexis) the leading work on bribery and corruption offences, and is co-authoring the chapters on Sanctions and MBD’s & their debarment systems in the revised edition, due 2025.
On the Attorney General’s Panel of Junior Counsel to the Crown, Sophie has advised HM Treasury, Foreign Commonwealth & Development Office, and Department for Business and Trade on sanctions and export control matters.
In 2023, Sophie acted for the Claimant in the first s.38 SAMLA challenge to a UK sanctions designation in the Administrative Court (Synesis v Secretary of State for FCDA [2023] EWHC 541 (Admin)). As a member of the UK Attorney General’s Panel, Sophie is regularly instructed by OFSI, HM Treasury and the FCDO to advise on sanctions matters.
Sophie is ranked as a Leading Junior in Business and Regulatory Crime (Including Global Investigations); Fraud; and POCA & Asset Forfeiture.
She co-authored the chapter on Economic Sanctions for Smith, Owen, and Bodnar on Asset Recovery (Criminal Confiscation and Civil Recovery), OUP and co-authored the chapter on the Bribery Act 2010 for the 3rd edition of Lissack and Horlick on Bribery (LexisNexis) the leading work on bribery and corruption offences and is co-authoring the chapters on Sanctions and MBD’s & their debarment systems in the revised edition, due 2025.
Sophie acts for companies and company officers regarding allegations of fraud, money laundering, bribery and corruption, tax evasion, insider dealing and sharp practices.
She conducts contentious work, appearing in crown and appellate courts, in addition to her advisory practice, providing opinions on legal issues including financial sanctions regimes, market manipulation and sharp practices, financial regulation proceedings and pre-charge advice.
She has particular experience in proceedings arising out of the Proceeds of Crime Act 2002 (POCA), acting for company directors and individuals in asset forfeiture and confiscation proceedings.
She has acted in a number of high-profile asset freezing and forfeiture matters, often with an international component involving allegations of institutional corruption and corporate bribery. Sophie is often instructed to advise corporates in the financial sector on prospective or actual regulatory breaches, particularly with reference to the UK’s Money Laundering Regulations and sanctions framework.
Given her experience in both commercial crime and civil regulation, Sophie is often instructed by specialist regulatory authorities to advise on the use and deployment of their statutory powers in a criminal and POCA context. Recently, Sophie has advised a series of UK regulators and prosecuting authorities in respect of the use of their powers to prosecute corporate entities and company officers for financial crime offences.
AH v JJ (2023)
Acting for the Defendant in High Court civil contempt proceedings arising from alleged breaches of >£6m freezing injunctions, preservation orders and financial undertakings. Jones v Hamilton[2023] EWHC 1216 (Ch).
Re: Y (2024)
Advising a significant UK based private equity investment group on criminal and regulatory risks in the context of financial sanctions compliance on the issue of corporate re-domiciliation.
Re: X (2023)
Advising a UK bank in respect of matters arising from the US prosecution of its account holders for forex manipulation and wire fraud offences.
The Pensions Regulator v SS & Others (2023-24)
Acting for the trustee of a corporate pension fund in one of the first criminal proceedings brought by The Pensions Regulator for offences under s40(5) of The Pensions Act 1995 relating to employer related loans and investments.
Operation Dynamite (Ongoing)
Acting for the Maritime and Coastguard Agency in one of its most ambitious and wide-ranging investigations into corporate financial crime and serious regulatory offences.
Re: B (2023)
Advising a global investment fund on litigation risks relating to AML compliance issues arising from a corporate client charged in the US with significant corporate financial offences.
Re: M (2023)
Advising an international mining company on the financial offences and sanctions risks arising from prospective commercial contracts with entities which may expose the client to US, EU and UK sanctions breaches.
SFO v Saghir Afzal (2020-23)
Instructed by the SFO in long-standing enforcement proceedings arising out of a £30 million confiscation order from convictions for major fraud and international money laundering offences.
RE: E (2022)
Advising a European investment firm in respect of regulatory and criminal risks arising from a cross-border criminal investigation into one of its financial services providers.
Sophie is ranked as a Leading Junior in Professional Discipline and Regulatory Law.
In domestic proceedings, she has advised and acted for those in the financial services, legal and medical professions in respect of misconduct investigations and contentious proceedings. She is frequently instructed in proceedings involving serious allegations of misconduct, sexual assault, dishonesty as well as health matters before the GMC, GDC, GPhC, NMC, SRA and MPS.
Sophie’s complementary expertise in criminal and regulatory law has meant that when instructed to act in conduct allegations which involve criminal behaviour, she often also appears in the crown court.
In addition to her UK professional disciplinary practice, Sophie also has specialist expertise acting for civil servants in professional disciplinary proceedings brought before international administrative tribunals, also involving allegations of serious misconduct including professional impropriety, high-value fraud and corruption charges. She has acted in proceedings brought against civil servants by international organisations including the International Monetary Fund (IMF), the European Bank for Reconstruction and Development (EBRD), International Fund for Agricultural Development (IFAD), UN Assistance Mission in Somalia (UNSOM) and the African Union Commission (AUC).
Z v IMF (2023-4)
Acting for IMF staff member in proceedings brought against the IMF relating to its conduct following an internal investigation.
X v IMF (2024)
Acting for senior IMF staff in proceedings brought against the IMF.
EBRD v A (2023-24)
Acting for a senior EBRD in disciplinary proceedings alleging serious misconduct.
IMF v B (2023)
Acting for a senior IMF employee in disciplinary proceedings alleging serious misconduct.
S v IMF (2023)
Acting for an IMF employee in a complaint brought against the IMF arising from findings of bullying and harassment in the workplace.
AUC v A (2021 – 2023)
Acting for a senior AUC employee in disciplinary proceedings alleging serious misconduct.
IFAD v F (2022)
Acting for a senior IFAD employee in disciplinary proceedings alleging serious misconduct.
GMC v Dr H (2024)
Acting for a leading cosmetic dermatologist in proceedings alleging myriad failings in clinical work and patient care.
GMC v Dr A (2023-4)
Acting for a obstetrics and gynaecology specialist against allegations of improper conduct.
GMC v Dr E (2022)
Acting for an allergy specialist accused of wide-ranging lack of competence allegations and specific allegations of misconduct relating to a vulnerable adult.
GMC v Dr X (2022)
Acting for a gynaecology and fertility specialist in proceedings relating to an allegedly improper and sexually motivated internal examination of a patient.
GMC v Dr Y (2022)
Acting for a cosmetic surgeon in regulatory proceedings accusing serious misconduct arising from improper procedures and breach of patient trust.
GMC v AK (2021)
Acting on behalf of a cosmetic surgeon in relation to multiple allegations of serious misconduct relating to surgical procedures and practices.
Sophie is ranked in the Legal 500 as a Leading Junior in Professional Discipline and Regulatory Law.
Sophie has broad experience appearing in criminal proceedings concerning health and safety breaches as well as criminal allegations arising from conduct in the workplace.
Sophie acts for companies, company officers and individuals, as well as the prosecuting entities, in regard to allegations of systemic failings in safe practices, serious injury and death in the workplace, and criminal allegations of professional wrongdoing and ill-treatment.
She is also instructed in coronial inquests and inquiries, often acting for government bodies as well as appearing on behalf of companies and company officers.
Operation Dynamite (Ongoing)
Acting for the Maritime and Coastguard Agency in relation to its largest investigation to date into the most serious and sustained health & safety and regulatory offences by a corporate, involving loss of life and serious injury to employees.
Inquest touching the death of DG (2024)
Acting for an NHS Trust in coronial proceedings arising from the death of a patient in an acute mental health ward.
Inquest touching the death of VH (2023)
Acting for the MoJ Probation Service in coronial proceedings arising from the death of an individual by suicide with complex mental health needs.
R (LFRS) v TK & Others (2023)
Acting for the corporate owner of a residential building for serious offences arising from fire safety failings.
HSE v FF (2022)
Acting for textiles corporate in proceedings arising from an explosion and fire at work premises in which an employee suffered life-changing injuries.
Thames Water (2022-24)
Acting for Thames Water in a series of corporate prosecutions for regulatory breaches by corporate bodies and individuals.
Sophie O’Sullivan is regulated by the Bar Standards Board (BSB) and holds a current practising certificate. If you are not satisfied with the service provided, please click here.
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