Partner
Tom Bushnell is a partner and barrister in the business crime and regulatory department, acting in complex financial crime, business crime and regulatory matters. Tom has been closely involved in some of the most significant financial crime cases of the last decade and draws on extensive experience prosecuting and defending such cases, both at Hickman & Rose and prior to joining the firm.
Tom was a key member of the Hickman & Rose team which acted for Carlo Palombo in his landmark, successful appeal to the Supreme Court (with Tom Hayes) against conviction in relation to EURIBOR and LIBOR. The Supreme Court overturned Mr Palombo and Mr Hayes’ convictions after the Court of Appeal had refused similar appeals against conviction on five occasions. Tom now advises four other traders on appeals in light of the Supreme Court’s decision. He was also part of the team which successfully defended the former Managing Director of G4S Care and Justice Services in criminal proceedings brought by the SFO.
Tom is an expert in contentious FCA cases and is particularly adept in situations where the FCA’s criminal and regulatory jurisdictions overlap.
Whilst at Hickman & Rose, Tom represented an individual who had referred a prohibition order and financial penalty to the Upper Tribunal, and advised a senior executive within a regulated firm on a high-stakes internal investigation. He has also advised multiple individuals on voluntary requests by the FCA for information in relation to trading; and represented three individuals under dual-track investigation for insider dealing/market abuse. One ended in no further action being taken; the second was settled at Stage 1; and the third is being contested before the RDC.
Whilst at the Bar (as a member of leading chambers Three Raymond Buildings) Tom was the FCA’s junior counsel in its investigation and prosecution of NatWest for breaches of the Money Laundering Regulations 2007. The case was the first time the FCA had prosecuted a large bank and culminated in the highest ever fine imposed on conviction in the UK (over £264m). He also advised the FCA on two significant insider dealing prosecutions and defended a third insider dealing trial against the FCA.
He is a contributing author to the prestigious Lloyd’s Financial Crime Reports, drafting headnotes and commentaries on significant recent decisions.
Tom is also well placed to advise when criminal or regulatory issues arise in relation to licensed premises and in the hospitality sector, having developed a busy licensing practice at the Bar. Recent work includes successfully avoiding prosecution for an innovative restaurant in Westminster following pest issues; and acting for a food production business and director in an extensive Food Standards Agency investigation.
Tom brings deep and practical experience of criminal litigation to all his cases. At the Bar, he regularly represented individuals accused of serious general criminal matters in the magistrates’ and Crown Courts: often professionals whose livelihoods were at stake.
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 both the Financial Services Lawyers Association and the Fraud Lawyers Association.
As a specialist financial crime barrister Tom works on the firm’s most significant fraud-related matters. He was 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; and is currently advising a former company director in relation to a complex s. 2 Notice.
Whilst in Chambers Tom was the prosecution junior in the FCA’s landmark investigation and prosecution of NatWest for breaches of the Money Laundering Regulations 2007, in which the bank pleaded guilty and was fined £264m. He spent six months in the agency’s Criminal Prosecutions Team during which he advised on a complex insider-dealing prosecution (FCA v Abdel-Malek and Choucair). He has also advised the FCA on a further insider dealing investigation, and defended an individual prosecuted by the FCA during a seven-week trial in 2022.
Tom also has significant experience of SFO prosecutions. He was part of the Hickman & Rose team which successfully defended the former Managing Director of Tesco UK on charges of fraud and false accounting brought by the SFO. Whilst a paralegal at Hickman & Rose, Tom worked on the successful defence of an individual charged by the SFO in relation to alleged LIBOR manipulation.
Tom’s financial crime experience also encompasses investigations. In 2018-2019, Tom spent six months as a part-time consultant to the regulatory and investigations group of a large international law firm where heavily involved in representing a corporate witness to a long running SFO investigation, liaising directly with the SFO case team and advising on responses to complex s. 2 notices. He also provided advice on matters spanning fraudulent trading in India, and
bribery/corruption in a South American country.
Tom is a member of the Young Fraud Lawyers Association and Financial Services Lawyers Association.
Tom is an expert in money laundering and the proceeds of crime. He advised the FCA throughout its
long and complex investigation into NatWest for breaches of the Money Laundering Regulations
2007: an investigation which led to the bank’s successful prosecution.
Tom has also advised a large international law firm which sought expert opinion in relation to
alleged money laundering in the insurance industry.
He has represented and advised both applicants and respondents on cash and account forfeiture
applications brought under the Proceeds of Crime Act 2002. Examples include advising a corporate
on a potential appeal against a forfeiture order; and advising the Metropolitan Police on resisting a
costs application following a decision to return a significant amount of detained cash.
Tom has significant experience in financial regulatory matters, especially those with fall under the
purview of the Financial Conduct Authority, an organisation with which, as a barrister in Chambers,
he has worked very closely.
Highlights include advising the FCA during its investigation into NatWest for breaches of the Money
Laundering Regulations 2007. The investigation culminated in criminal prosecution and guilty pleas,
with the bank being fined over £264m.
Tom also regularly advised on various aspects of FCA regulation and enforcement. In 2018-2019 he
spent six months as a consultant to the regulatory and investigations group of a large international
law firm, assisting on a number of its ongoing FCA cases. His advice included on SUP15 notifications
and responding to ongoing investigations by Supervision and Enforcement.
During his time as a paralegal at Hickman & Rose, Tom was heavily involved in the defence of a trader who was exonerated by the FCA’s Regulatory Decisions Committee for alleged LIBOR manipulation. Once at the Bar, Tom was instructed to assist with the individual’s complaint to the Financial Regulators Complaints Commissioner about Enforcement’s conduct of the case: the Complaints Commissioner upheld the complaint, finding “serious shortcomings” in the way that the FCA had handled it.
Tom is an expert in insider dealing and market abuse. His experience spans allegations of low-level, opportunistic insider dealing to sophisticated, complex conspiracies.
Tom is currently representing two clients under investigation by the FCA for insider dealing/market abuse.
He draws on extensive experience of both prosecuting and defending insider dealing cases whilst at the independent Bar.
In 2018, he spent six months on secondment from Chambers to the Criminal Prosecutions Team of the FCA. During and after the secondment, he assisted the FCA on its successful prosecution of a compliance officer at a global bank and a day trader (FCA v Abdel-Malek and Choucair). Following that, the FCA instructed Tom to advise on an ongoing, complex investigation into suspected insider dealing.
In 2022, Tom represented the second defendant in a seven-week insider dealing trial at Southwark Crown Court (in which the jury was discharged after failing to reach a verdict).
2 Mar 2026
Business crime and regulatory partner Tom Bushnell has analysed a major High Court judicial review / costs case in the latest 2026 edition of Lloyd’s Law Reports: Financial Crime.
In R…
24 Feb 2026
Business crime and regulatory partner Tom Bushnell has been quoted in the Financial News in respect of new data showing a 21% decline in the number of insider dealing Suspicious Transaction and…
29 Jan 2026
The Criminal Cases Review Commission has referred the LIBOR and EURIBOR related convictions of five individuals, of whom three are Hickman & Rose clients, to the Court of Appeal.
Jay Merchant,…
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