Tim Thomas

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Tim Thomas

Director
Of Counsel
Tim is a Director of the firm and Head of the Financial Services Regulatory department.  He is regularly instructed by domestic and overseas clients to represent their interests in enforcement proceedings brought by U.K. financial regulators as well as advising on non-contentious matters such as Senior Managers and Certification Regime (SMCR) compliance.

Tim has considerable experience in financial service regulatory matters both in the contentious and non-contentious sphere. He brings a unique knowledge of the enforcement investigation process having successfully acted against the FCA’s Enforcement & Market Oversight Division (EMO) before being seconded and employed by EMO between 2015 and 2019.  During that time Tim worked on Retail Enforcement Investigations into Connaught, Paul Flowers, Standard Chartered and HBOS before becoming a member of the Criminal Prosecutions Team, where he advised enforcement investigation teams in the Retail, Wholesale and Unauthorised Business departments on over thirty dual-track investigations into breaches of the Financial Services & Markets Act 2000 (s19 general prohibition) and the Money Laundering Regulations 2017, the Financial Services Act 2012 (s89-90 Market Abuse) and the Criminal Justice Act 1993 (Insider Dealing),  including Telit Plc and Al Rayan Bank. He also advised the Authorisations and Financial Crime Specialist Supervision departments in relation to individual SIF applications (FIT).

His roles in EMO involved regular liaison with the Pensions’ Regulator and HMRC in the UK as well as the like CBI (Ireland), MAS (Singapore), SEC and DoJ (US).

Notable Cases

FCA v D

Acting for a company director in criminal proceedings for breach of FSMA in relation to a Collective Investment Scheme. The client received a suspended custodial sentence for breaching s19 of the Financial Services & Markets Act 2000.

Standard Chartered

FCA investigation into Anti Money Laundering failings in Standard Chartered’s UK Wholesale Bank Correspondent Banking business and its branches in the United Arab Emirates (UAE). The investigation led to a £102m fine.

Paul Flowers

Individual conduct case brought by FCA against former chairman of Co-op Bank. Mr Flowers was prohibited from working in the financial services sector as a result of the FCA finding of a lack of fitness and propriety.

Telit

FCA investigation into the timeliness of market announcements by AIM listed enabler of Internet of things and machine to machine communications company.

UMBS

Successful defence of a company director of a Credit Union accused of fraudulent trading and money-laundering.