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Sara Lawson KC

Barrister
Financial Crime, Risk Advisory & Internal Investigations

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Sara Lawson KC has over 30 years’ experience in financial and regulatory crime, having worked on her first SFO fraud case in 1993. Sara can assist companies with investigations from whistleblowers, reviewing corporate due diligence, policies and training, as well as how and whether to navigate any referral to agencies. She has worked with Boards (and was an executive board member herself at the SFO), ever conscious of reputational risks as well as legal and financial risks which companies face.

As the most senior lawyer and joint number 2 at the SFO, as General Counsel, she signed off 8 of the SFO’s total 12 DPAs (deferred prosecution agreements). Her extensive experience as Standing Counsel to the Insolvency Service and prosecuting and defending HSE and Environment Agency cases means that she is used to advising on corporate risk assessments as well as actual incidents.

Sara worked on the SFO’s new corporate guidance which takes account of the new failing to prevent fraud offence and new corporate criminal liability test, both introduced by ECCTA (the Economic Crime and Corporate Transparency Act 2023). As GC Sara advised SFO investigators and lawyers on the course of cases pre and post charge and worked closely with national and international law enforcement agencies, particularly the US DOJ. Working on civil recovery as well as confiscation of criminal assets was also a large element of her SFO work. Nearly all the cases she oversaw involved international evidence and co-operation. Most of the SFO DPAs involved international bribery and corruption although fraud is likely to be more prevalent than bribery offences for UK companies or international companies with a UK nexus.

Sara also signed off SFO corporate guilty pleas (and was party to negotiations in some) which involved multi-million-pound agreements to propose to the Courts and were often impacted by ongoing civil litigation as a factor for parties to consider. As a senior decision maker and appeal point for internal and external complaints involving SFO staff, and reviews of SFO decisions, Sara is used to delicate internal investigations of sensitive matters, sometimes with the added pressures of publicity. Sara has both appointed and worked with Government-appointed reviewers and investigators.

With the Insolvency Service Sara worked on pursuing companies and directors who had misused the process including prosecuting dishonest insolvency practitioners. As a junior and in silk Sara also defended these cases looking at what can go wrong once a company has financial difficulties. As a recognised expert she also drafted papers for Practical Law on various aspects of the Insolvency Act and is a contributor for the 2025 edition of the Oxford University Press Encyclopedia of Fraud.

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