David Hamilton

He specialises in regulatory investigations and enforcement and financial crime defence. He advises financial institutions, listed companies, corporates, senior managers, and other regulated individuals on complex internal investigations, regulatory enquiries, and high-profile enforcement proceedings.

With more than 17 years' experience, David has represented clients in matters involving regulators and enforcement authorities including the Financial Conduct Authority (FCA), Serious Fraud Office (SFO), HM Revenue & Customs (HMRC), the European Commission, and the US Department of Justice. His practice spans market abuse, insider dealing, fraud, bribery and corruption, money laundering, tax-related crime, and governance-related investigations.

David has acted on some of the most significant regulatory and criminal investigations of recent years, including the LIBOR and foreign exchange investigations, cross-border tax enforcement actions, insider dealing and market abuse cases, fraudulent trading prosecutions, and major systems and controls reviews. He also advises organisations across a broad range of sectors on internal investigations involving allegations of misconduct, financial crime, regulatory breaches, and broader governance concerns.

Clients value David for his ability to combine technical regulatory expertise with pragmatic, commercially focused advice. He helps businesses and individuals navigate complex investigations, manage legal, regulatory and reputational risk, and engage effectively with regulators and enforcement authorities. His experience enables clients to take informed strategic decisions during periods of intense scrutiny and achieve outcomes that support their long-term objectives.

Jurisdiction: England & Wales

• Representing the CEO and CFO of a payments institution in parallel FCA enforcement investigations following a Skilled Person review into alleged deficiencies in the firm's AML framework, successfully securing the discontinuance of both investigations.
• Conducting an internal investigation for a fund manager into allegations that former employees misrepresented portfolio asset performance to investors. Advising on engagement with the FCA, remediation issues, and managing related regulatory, litigation, and reputational risks.
• Representing a professional independent trustee in connection with an FCA fraudulent trading prosecution, advising the client in its capacity as a key prosecution witness.
• Representing an ultra-high-net-worth individual in a four-year cross-border tax evasion investigation by HMRC. Advised throughout the matter, including interviews under caution, managing a dawn raid, and engaging with enforcement authorities, securing the discontinuance of the investigation and return of assets worth over £1 million seized by UK Border Force.
• Advising a SIPP operator facing multiple Financial Ombudsman Service (FOS) complaints regarding historical due diligence failings, supporting the FOS process, negotiating voluntary requirements with the FCA, and facilitating the sale of the business.
• Representing a portfolio manager in relation to an FCA market abuse investigation arising from a debt issuance wall-crossing, preparing the client for interview and making detailed written representations to the FCA, securing the discontinuance of the investigation.
• Advising companies, entrepreneurs and high-net-worth individuals on account freezes, de-banking, and financial crime-related risk issues.
• Advising companies spanning insurance, payments, money remittance, investments, estate agency, energy and construction, on the design, implementation and remediation of financial crime compliance programmes, including AML, anti-bribery, fraud, and tax evasion prevention.