Tom Bushnell

Tom Bushnell is an associate and barrister in the business crime and regulatory department who specialises in serious corporate and financial crime, and associated regulatory matters. Tom draws on extensive experience prosecuting and defending such cases prior to joining Hickman & Rose.

Tom’s recent and ongoing work includes:

• Acting for Carlo Palombo in his landmark appeal to the Supreme Court (with Tom Hayes) against conviction in relation to EURIBOR and LIBOR, and advising three other traders whose convictions will be directly impacted by any decision;
• Advising three individuals on ongoing market abuse investigations by the FCA, and a fourth under investigation for alleged criminal insider dealing;
• Advising an individual under suspicion in a high-profile SFO investigation;
• Representing an individual who has referred enforcement action by the FCA to the Upper Tribunal;
• Representing an individual under investigation by the FCA in relation to alleged unauthorised business;
• Representing businesses and individuals under investigation for food safety offences in both the food production and high-end hospitality sectors;
• Advising a company executive under investigation by a private prosecutor.

Tom was also part of the Hickman & Rose team which successfully defended the former Managing Director of G4S Care and Justice Services in criminal proceedings brought by the SFO. The case ended when the SFO offered no evidence before trial, having entered into a DPA with G4S Care & Justice Services (UK) Ltd in relation to the same conduct.

Tom joined Hickman & Rose in August 2022. Before that, he spent six years as a member of leading barristers’ chambers Three Raymond Buildings where he was instructed on complex financial crime cases and acted for both prosecution and defence.

He gained particular experience in FCA matters. He was the FCA’s junior counsel in its prosecution of NatWest for breaches of the Money Laundering Regulations 2007. The case was the first time the FCA had brought a criminal prosecution for breaches of the MLR 2007 and the first time the FCA had prosecuted a large bank. Tom advised throughout the investigation, charging decision, plea discussions and sentencing. The case culminated in the highest ever fine imposed on conviction in the UK (over £264m).

He advised the FCA on two significant insider dealing prosecutions, and defended a third insider dealing trial against the FCA. In 2018, he carried out a six month secondment within the FCA’s Criminal Prosecutions Team.

Tom gained experience in cash and account freezing/forfeiture applications brought under the Proceeds of Crime Act 2002. He has given advice and represented clients on a range of sanctions matters, including advising a company and senior individuals within it on an investigation by the NCA into alleged breaches of Ukraine/Russian sanctions; and advising an international law firm on representing an individual designated overseas.

Tom also regularly represented individuals accused of serious general criminal matters in the magistrates’ and Crown Courts: often professionals whose livelihoods were at stake.

In addition to crime, Tom developed a busy licensing practice at the Bar. He regularly advised and acted for operators, the police, local authorities and local residents before licensing sub-committees and on appeal. He therefore remains particularly well placed to advise when criminal or regulatory issues arise in relation to licensed premises or holders of personal licences.

Tom studied law at Trinity Hall, Cambridge, where he graduated with a first and received multiple scholarships and prizes. He completed the BPTC at Kaplan Law School, received an ‘Outstanding’ overall and was awarded a Certificate of Honour by Middle Temple.

Tom is a member of the Young Fraud Lawyers Association and Financial Services Lawyers Association.