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Anne-Marie Ottaway

Anne-Marie Ottaway is a white-collar defence and investigations attorney with over 20 years’ experience, including 13 years at the UK’s Serious Fraud Office, and was the Specialist Adviser to the House of Lords’ Select Committee on the Bribery Act 2010.

Ranked in both Chambers and the Legal 500, she has deep experience with economic crime related matters and provides clients with advice on all aspects of government investigations and prosecutions, with a particular focus on allegations relating to fraud, bribery and corruption, insider dealing, market abuse and money laundering.

Anne-Marie is highly experienced in conducting internal investigations and advising on corporate self-disclosures and related reporting obligations. She also provides advice to corporate clients in respect of the design and implementation of effective compliance programmes.

She has advised individual suspects and witnesses in a number of Serious Fraud Office (SFO), Financial Conduct Authority (FCA), HM Revenue and Customs (HMRC) and Information Commissioner’s Office (ICO) investigations and prosecutions.

Formerly a prosecutor at the SFO, Anne-Marie worked on some of the UK’s largest fraud and corruption investigations and prosecutions. She worked on a number of international investigations, involving cooperation with the United States’ Department of Justice and Securities and Exchange Commission, European and Swiss Federal Prosecutors, the Australian Federal Police, and organisations such as the World Bank. Among her duties at the SFO, she played a key role in the early development of the SFO’s self -reporting regime and served as the SFO representative on the cross government strategic group for money laundering involving politically exposed persons (PEPs) and the law enforcement co-ordination group on overseas corruption.

In 2018 Anne-Marie was appointed as the Specialist Adviser to the House of Lords’ Select Committee on the Bribery Act 2010, which conducted a post-legislative review of the Act, its impact on companies and the effectiveness of enforcement, including scrutiny of the use of Deferred Prosecution Agreements. The Committee’s report was published in March 2019.

Anne-Marie is recognized by Chambers & Partners for her “expertise in financial crime issues”, her “extensive government experience” and “reputation for defending corporate clients subject to fraud and bribery allegations” and is ranked by Legal 500 as a leading individual for Regulatory Investigations and Corporate Crime.

Capabilities

Experiencia

  • Advising an individual subject to an Account Freezing Order obtained by the Metropolitan Police under part 5 of the Proceeds of Crime Act 2002.
  • Advising a corporation under investigation by the Serious Fraud Office linked with the ongoing DOJ and SEC investigation into Unaoil bribery allegations.
  • Advised a financial services firm in connection with a Financial Conduct Authority investigation into suspected “printing” and “flying”.
  • Provided advice on insider dealing and market abuse risks to an overseas company in connection with the proposed acquisition of a UK listed entity.
  • Advised an investment group on potential UK criminal law risks connected to a proposed investment in cannabis businesses in jurisdictions where the recreational use has been legalised.
  • Advised a European headquartered company in connection with a HMRC COP8 investigation into one of its UK subsidiaries.
  • Represented a corporation in the infrastructure sector in the first failure to prevent bribery prosecution following claims of non-cooperation by the SFO and the refusal of the SFO to offer a Deferred Prosecution Agreement (DPA). Resolved matter in under a year. The case was successfully disposed of with a lower penalty and less onerous conditions than the preceding DPA. The case threw into sharp relief the lack of incentive, in certain circumstances, of entering into a DPA to dispose of a criminal offence and sparked a debate into the DPA ‘offer’ and further discounts in DPA’s which followed.°
  • Advised a Scottish based company in connection with the first part 5 Proceeds of Crime Act 2002 civil recovery action by the Scottish Crown Office for a section 7 Bribery Act 2010 offence.°
  • Conducted an internal investigation on behalf of a financial services company into suspected fraud by senior employees and advising them on their interactions with the Prudential Regulatory Authority and Financial Conduct Authority.°
  • Advised a cash and derivatives brokerage firm in connection with the Serious Fraud Office's and Financial Conduct Authority's LIBOR investigations.°
  • Represented a UK plc in connection with the Information Commissioner’s Office Operation Spruce investigation into suspected data protection breaches under s.55 of the Data Protection Act, which outlaws knowingly or recklessly obtaining or disclosing personal data without the consent of the data controller, resulting in no action being taken by the ICO.°
  • Represented a FTSE 250 company and conducting an internal investigation in respect of potential breaches of UK Bribery legislation in one of its South East Asian subsidaries.°
  • Conducted an internal investigation into potential breaches of UK Bribery legislation on behalf of a European company in the infrastructure sector.°
  • Advised a range of UK and international companies on the implementation of anti-bribery and corruption compliance programmes.
  • Advised a range of UK and international companies on the provisions of the UK Proceeds of Crime Act and related mandatory or voluntary disclosures to the National Crime Agency.
  • Provided advice to a range of UK and international companies on anti-fraud and corruption due diligence in a range of transactions.
  • Conducted detailed bribery and corruption risk assessments on behalf of clients.°
  • Provided Anti-bribery and corruption training to clients, both at senior management level and to their wider employees.°
  • Advised on ABC due diligence in the context of mergers and acquisitions and advising on ABC wording for contracts with JV partners and other third parties.
  • Advised a client regarding a Financial Conduct Authority insider dealing investigation.°
  • Provided advice on anti-money laundering internal controls and on related reporting obligations.°

°The above representations were handled by Ms. Ottaway prior to her joining Greenberg Traurig, LLP.

  • Specialist Adviser to the House of Lords Select Committee on the Bribery Act, 2018-2019
  • Serious Fraud Office (SFO), 1999-2012
    • Case Controller (Prosecutor), 2008-2012
    • Investigative Lawyer, 2003-2008
    • Trainee Solicitor, 2001-2003
    • Investigator, 1999-2001

Recognition & Leadership

  • Listed, Chambers UK Guide, 2014-2020
    • Listed, “Financial Crime: Corporates, Band 4”, 2019-2020
    • Listed, “Financial Crime: Corporates, Up and Coming,” 2017-2018
    • Listed, “Financial Crime: Corporates, Star Associate”, 2016
    • Recognised, “Financial Crime: Corporates”, 2015
    • Listed, “Financial Crime: Corporates, Associate to Watch”, 2014
  • Listed, The Legal 500 UK, 2014-2019
    • Leading Individual: London Risk Advisory, “Regulatory Investigations and Corporate Crime”, 2018-2019
    • Recommended: London Crime, Fraud and Licensing, “Fraud: White Collar Crime”, 2014-2017 
  • Recognised, The Times, Best Law Firms 2020: Financial crime, fraud and regulatory
  • Listed, Who's Who Legal, Investigations: Lawyers, 2017-2019
  • Listed, Who's Who Legal, Thought Leaders – Investigations, 2018-2019
  • Listed, Who's Who Legal, Business Crime Defence: Corporates, 2017-2019
  • Listed, Who's Who Legal, Thought Leaders - Business Crime Defence: Corporates, 2019
  • Listed, Global Investigations Review, as a Top 100 Women in Investigations, 2018
  • Listed, Expert Guides, “Rising Stars: White Collar Crime,” 2018
  • Member, the Fraud Lawyer’s Association
  • Member, the Women’s White-Collar Defense Association
  • Liveryman, the City of London Solicitors’ Company

Credentials

Educación
  • LPC, College of Law, 2000
  • LL.B. (Hons), London Guildhall University
Con licencia para ejercer en
  • England and Wales