Accountability in action — FCA’s enforcement against Monzo & Barclays explained
Recent FCA enforcement actions highlight systemic weaknesses in financial crime controls across both traditional and digital banking models.
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Business life is never straightforward. An internal or external whistle-blower incident or uncovering malpractice, bribery, tax irregularities or fraud in your business inevitably poses a number of difficult practical, legal and emotional challenges.
Not only might it expose your business to financial loss or the potential for civil proceedings, but there is always the risk that such conduct could expose your business to regulatory or criminal enforcement.
The need to conduct an internal investigation arises in many cases, regardless of whether your business is in the regulated sector. In doing so, you may be able to regain some control, enabling your business to establish the facts and make informed decisions — whether in relation to:
- assessing corporate and individual risk (bribery, tax irregularities, theft, fraud or other misconduct)
- self-reporting to law enforcement
- making suspicious activity reports
- initiating disciplinary proceedings
- identifying financial loss
- commencing civil proceedings to recover losses.
Our services
- Conducting internal investigations with legal professional privilege.
- Gathering and managing evidence in an evidentially sound way, so that it's preserved in the event that civil or criminal proceedings are launched.
- Obtaining necessary external expert evidence, including forensic computer specialists and forensic accountants.
- Preparing internal reports to Board members on misconduct, regulatory criminal breaches, risk and compliance or NEDs as required.
- Preparing and conducting interviews with suspects and obtaining witness evidence.
- Advising on the necessary reporting obligations, including anti-money laundering, self-reporting of fraud and bribery and reporting to regulators.
- Representing businesses and individuals, should external law enforcement commence investigations.
- Dealing with whistle-blowing issues.
- Advising on employment-related issues, including suspension, disciplinary proceedings and liaising with regulators and law enforcement.
Experience across a range of industries
Steel company — conducting internal investigations & advising corporate clients on liability in relation to highly sensitive police investigations into allegations of corruption in a tender process for the supply of steel.
Digital distributor of insurance services — conducting an internal investigation on behalf of and providing advice to a corporate entity in respect of alleged bribery within departments that involves external suppliers, including self-reporting and anti-money laundering.
Logistics companies
- Internal investigations on behalf of and providing advice to a corporate entity following the discovery of fraud within a subsidiary company, including anti-money laundering reporting and internal investigation.
- Internal investigations following allegations of bribery and theft of confidential information. Recovery of laptop computers phones, .pst files and homeshares by forensic experts. Hosting and review of material. Advice in respect of self-reporting, legal professional privilege and criminal issues arising including risk, reasonable lines of enquiry, interviews, suspension of staff and the obtaining of witness evidence. Preparation for interview under caution (criminal). Pre-interview disclosure. Advising NEDs Audit & Risk, Group Counsel. Witness statements.
Mobile phone/airtime industry — internal investigations following discovery of possible bribery being perpetrated by senior staff. Recovery of computer data, laptops, mobile phones by forensic specialists. Working with employment lawyers in relation to staff suspension and commercial lawyers on contract issues. Advice in respect of self-reporting, anti-money laundering, legal professional privilege, suspension of staff and criminal property.
Charitable trust — advising on reporting of fraud and allied anti-money laundering issues.
Local authority — providing advice following discovery of multi-million pound fraud. Referral to authorities resulting in successful prosecution by the SFO.
Corporates — civil fraud recovery matters in cases involving the theft of approximately £10 million. Obtaining ex parte search and seizure orders and freezing orders.
Recognised as a top-tier firm in The Legal 500 2025
“Dan Stowers leads the team focusing on business crime and compliance and has vast experience in defending serious fraud cases and financial crime compliance issues.”
The Legal 500 2025
“[Dan Stowers is] highly experienced in all aspects of fraud work and is head and shoulders above his peers… a leader in the field.”
The Legal 500, 2012
“Dan Stowers is clearly in control of his cases. He has the exceptional ability of both being able to have a well-reasoned overview of a case as well as having all the details at his fingertips. This means that you feel that he is truly providing the best representation for his client.”
The Legal 500, 2020
“Dan Stowers is without doubt the most dynamic lawyer in his field, understanding the issues immediately and how to address them.”
The Legal 500, 2020
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