James Thomas

Senior Associate
Norton Rose Fulbright LLP

United Kingdom
T:+44 20 7444 2470
United Kingdom
T:+44 20 7444 2470
James Thomas

James Thomas



James Thomas is a regulatory compliance, dispute resolution, and investigations lawyer based in London. He focuses on financial crime, anti-bribery (UK Bribery Act), anti-corruption, supplier due diligence, anti-money laundering, proceeds of crime (POCA), economic sanctions, prevention of facilitation of tax evasion (Criminal Finances Act), human rights, modern slavery, privacy, data protection and cybersecurity.

James has been seconded to the financial crime compliance teams of three global banks and one major corporate, where he designed and implemented compliance programmes.  James advises on the financial crime-regulatory aspects of M&A and joint ventures, including due diligence. James has conducted mandates in China (Shanghai and Hong Kong), Singapore, South Africa, India, Russia, the United States, Canada, Dubai, Qatar, and throughout Europe.

Having practised as a barrister, James represents financial institutions (banks, private equity, (re)insurers, brokers), corporates (mining, oil & gas, engineering) and ‎senior executives in commercial litigation and alternative dispute resolution (arbitration and mediation), usually high-value, multi-jurisdictional matters with elements of financial crime.

James conducts major regulatory and criminal internal investigations in matters involving the UK Serious Fraud Office (SFO), Financial Conduct Authority (FCA), the US Department of Justice (DOJ), US Federal Reserve Board (FRB) and other regulators. 

James is a friend of the UK law reform and human rights organisation JUSTICE.

Professional experience

Expand all Collapse all
  • London School of Economics, Masters in Law (LLM), papers in International Criminal Law, International Commercial Law, Compensation, and Civil Procedure.
  • Oxford University, degree in Philosophy, Politics and Economics.
  • Solicitor,Advocate, qualified in England & Wales
  • Global bank: reviewing client onboarding files for compliance with Canadian anti-money laundering requirements.
  • Global management consultancy: nine-month anti-corruption internal investigation in South Africa (State Capture), concerning Black Economic Empowerment (BEE) partners.
  • International banks and private equity firms: conducting risk assessments, designing compliance programmes and drafting contractual clauses to comply with the Corporate Criminal Offence (CCO) under the UK Criminal Finances Act (CFA) (failure to prevent facilitation of tax evasion).
  • African state-owned diamond mining company: dispute resolution and corporate advice relating to joint venture.
  • Oil & Gas Major: dispute resolution in context of a consultant operating in Qatar.
  • Global bank: one year secondment in anti-bribery and corruption team, designing anti-corruption procedures for third party consultants and introducers in the context of an FCA supervisory visit; advising the bank on corruption risks of agents in Middle East, Latin America and China; delivering training to first line and second line of defence staff in New York, Frankfurt, Singapore and Hong Kong.
  • Global bank: six months secondment on the data privacy issues arising from the bank's AML and sanctions compliance systems.
  • Global engineering company: Conducting on-site anti-corruption risk assessments in China, India, Ukraine, Kazakhstan and the United States, including interviews with executives and sales staff. Drafting reports for the client's audit committee. Designing and operating procedures on due diligence on third party agents, introducers and distributors.
  • Global vehicle manufacturer: conducting internal risk assessment of corruption risk at Shanghai sales office.
  • Global French-headquartered company: conducting anti-corruption risk assessment under Sapin II.
  • Chief Executive of Lloyd's Managing Agent: acting in misconduct proceedings brought by Lloyd's of London
  • Tips for a third party anti-corruption due diligence database - Financier Worldwide Magazine
  • Briefing on UK Ministry of Justice guidance on the Bribery Act
  • Institute of Money Laundering Prevention Officers on developments in financial crime, including failure to prevent tax evasion.
  • Lloyd's Market Association on the UK Bribery Act.


Managing third party corruption risk

Publication | February 2017