Guy Wilkes

Guy is a partner in the Financial Services Regulation group and leads the firm's Financial Services Investigations and Enforcement practice.

Guy specialises in regulatory disputes, particularly involving financial and professional services and has been involved in some of the FCA and PRA's highest profile investigations against both individuals and institutions. 

Guy conducts and advises clients on internal investigations, including those involving directors and senior managers. He also provides compliance advice to firms, particularly where it involves supervisory intervention by the FCA and PRA, change of control applications and issues involving application of SMCR rules. He provides AML advice to all regulated sectors.

He was formerly a member of the FCA's senior leadership team and had responsibility for developing enforcement strategy, especially in relation to financial crime and anti-money laundering where he chaired the cross-divisional working group. While at the FCA, Guy set up and ran an internal expert group for investigations against senior individuals and chaired the FCA's insolvency expert group.

His regulatory experience involves a wide range of matters including AML, financial promotions, listings rule breaches, conflicts of interest, suitability of advice, treatment of customers, client asset rules, market misconduct, unauthorised business and personal culpability of individuals as well as matters in the gambling and professional sectors.

Guy's court experience is extensive and includes civil litigation before the Court of Appeal and Supreme Court in cases involving regulatory disputes, fraud, asset tracing, insolvency, and commercial disputes.

Guy is recommended as a leading individual in Legal 500 and ranked "band 1" by Chambers & Partners.

Guy is a member of the Insolvency Practitioner's Association Disciplinary and Appeals Committee, is a member of the Law Society's Economic Crime Committee and sits on the Lexis/Nexis editorial board for financial services. He is a regular media commentator on Financial Services Regulatory matters.

Key Experience

Recent investigations/experience includes:

• Acting for a bond trader in Urra & Ors v Financial Conduct Authority
• Acting in a judicial review application (R(CIT) v Financial Conduct Authority) in relation to the FCA's new publicity policy
• Acting for Meritus Trust Company in disciplinary proceedings with the Bermuda Monetary Authority
• Acting for the administrators of London Capital and Finance Plc.
• Providing strategic and English law advice to a director under investigation by the Gibraltar Financial Services Commission
• Representing firms subject to supervisory action by the FCA including imposition of requirements and appointments of skilled person
• Representing firms in a number of "perimeter cases" involving allegations of unauthorised business.
• Advising a number of CFD firms under investigation by the FCA.
• Representing firms and individuals subject to investigation by Lloyd's
• Acting for firms and individuals subject to ICAEW investigations.
• Advising regulated firms and senior employees in connection with employment disputes.
• Leading an investigation into the Open Banking Implementation Entity following allegations of misconduct (the Alison White report).

Advisory work includes:

• Providing advice to the Alpha Auto Group and Global Auto Holdings Limited on the FCA regulatory business plan and FCA change in control application for the acquisition of listed company Lookers plc.
• Advising a debt advice firm on remediation work – including undertaking a past business review.
• Advising a leading crypto firm on putting in place systems and controls to comply with FCA financial promotion rules.
• Advising on applications for FCA AML registration including drafting of appropriate policies and procedures.
• Advising on applications for senior manager approval.

Career History

Partner, Mishcon de Reya LLP
Partner, Mayer Brown International LLP
Acting Head of Department, Financial Conduct Authority
Associate, Osborne Clarke LLP
Associate, Allen & Overy LLP