Gemma Tombs

White Collar and Financial Crime

Gemma has been involved in many high-profile investigations and prosecutions brought by the SFO, the CPS, the FCA and HMRC for offences including tax fraud, cheating the public revenue, insider dealing and bribery and corruption.

Proceeds of Crime and Money Laundering

Gemma frequently advises on the UK’s anti-money laundering regime and the impact of the Proceeds of Crime Act and the Money Laundering Regulations 2017. She has worked with many organisations on their regulatory obligations including those in the education sector, the art world and the gambling industry.

Gemma also has extensive expertise in challenging civil recovery investigations and proceedings including Account Freezing and Forfeiture Orders.

Sanctions Advice

Gemma has particular expertise in sanctions-related matters and advises on the impact of sanctions not only on designated persons but also the individuals and businesses they are linked to. Gemma’s work in this area includes advising on the risk of sanction breaches, reporting obligations and obtaining specific licences from OFSI.

Internal Investigations

As part of the Internal Investigations team, Gemma is an expert in conducting internal investigations on behalf of corporate clients, from the initial scoping to the evidence gathering and reporting stages.

Publications, Press Highlights & Speaking Engagements

• Quoted in Money Laundering Bulletin
• AML in the Art World – The Latest Update & Guidance – MBL webinar
• Anti Money Laundering: Shining a Spotlight on Compliance – This article first appeared in the July 2022 issue of PLC Magazine.
• New anti-money laundering standards can also help sanctions find their Russian targets, Quoted in the Financial Times, March 2022
• FAFT wants countries to set up ownership registers, Quoted in Law Society Gazette Magazine, March 2022
• A new Economic Crime Bill and the accelerated introduction of a Register of Overseas Entities, February 2022
• Ukraine war accelerates Companies House reform, Quoted in accountingWEB, March 2022
• The compulsory embrace of the art market by the UK’s Anti-Money Laundering regime, June 2020
• Fraud in the time of COVID-19, April 2020
• Consultation on the revisions to the Attorney General’s Guidelines on Disclosure and the CPIA Code of Practice – Interviewed by LexisNexis, April 2020

Professional Societies & Memberships

• LCCSA
• FLA
• WWCDA
• WICL