Sam Tate

A leading regulatory and investigative lawyer helping clients resolve complicated issues efficiently in the areas of corruption, fraud, sanctions, money laundering, compliance, private prosecutions, complex investigations, criminal proceedings, asset tracing, civil fraud, crisis management and FCA enforcement.

Sam completed the ground-breaking 11th and 12th UK DPA’s and the independent investigation initiated by the Financial Times regarding allegations made against its reporters by Wirecard. He leads a practice area at Clyde & Co working with states, corporates, insurers, investors and individuals. He held significant roles in two global AML/ sanctions focused monitorships (US DoJ/UK FCA/US FRB), including the HSBC monitorship which was the most complex and largest of its kind.

Sam previously led Exiger’s Anti-Corruption and investigative EMEA practice where he worked with Lisa Osofsky, later Director of the SFO. Prior to Exiger, Sam was the In-house expert at BP Plc resolving ABC/AML issues in higher risk jurisdictions around the world and numerous overseeing cross-border investigations. He has practical experience with civil and criminal proceedings, SFO/FCA processes, implementing diligence/risk assessment tech., PE, investments diligence (e.g. a USD 20 billion Russian matter), advising on FCA and s166 investigations and managing risk in joint ventures. He has also spent time at US investment bank (Morgan Stanley) up to and after the crash of 2007/2008 and regularly leads investigations in Africa, Asia, the Middle East, Europe and Russia.

Sam was for many years a visiting lecturer on the Durham University LLM/LLB courses. He is also a conference speaker (e.g. New Scotland Yard, ABA, C5, IBA and AMLP), provides input to government reviews, sat on TI’s risk assessment panel, is an honorary member of the Institute for Commercial and Corporate Law and certified Lead Auditor for ISO37001.

Sam is co-author of the leading textbook “The UK Anti-Bribery Handbook” Bloomsbury, 2022, described as “a first rate guide for all legal practitioners called upon to advise on any issue concerning bribery”.

Experience

• JLL in relation to a deferred prosecution agreement with the UK Serious Fraud Office for corrupt payments following a lengthy investigation.

• On sanctions and AML reviews as part of the US/UK and French monitorships of HSBC and Credit Agricole.

• The Financial Times and Channel 4 in relation to complex internal investigations.

• The City of Neom, KSA, in relation to its financial crime and ESG program and related technology.

• The Republic of Nigeria in relation to the payment of compensation relating to bribery issues.

Publications

The UK Anti-bribery Handbook, published by Bloomsbury

Memberships

City of London Law Society Corporate Crime Sub-Committee Member