Findley Penn-Hughes

Findley Penn-Hughes, senior associate, is dual-qualified in the US and UK and has practiced in both London and New York. He advises multinational companies on compliance, investigations, and white-collar defense matters across multiple jurisdictions.

Findley's practice focuses on representing and defending corporations and individuals in white-collar criminal matters and cross-border investigations (both internal and government-facing), and providing proactive compliance program counseling to global clients, including the design, implementation, and ongoing assessment of compliance programs across a wide range of regulatory disciplines (including anti-corruption, AML, sanctions, antitrust, and trade compliance). Findley also advises clients on the use of AI and data analytics in compliance monitoring and risk assessment.

Investigations, White Collar Defence & Compliance

• Advising a US-headquartered biotechnology, chemicals, and pharmaceutical company on the enhancement of its third party management program, including training and related internal controls
• Advising, and was seconded to, a global technology and engineering company in connection with the enhancement and testing of its global anti-corruption compliance program, various ad-hoc internal investigations, remediation of identified issues and preparation of compliance presentations and post-resolution reports to U.S. and global regulators
• Advising an India-based client on enhancements to its anti-bribery compliance program, including the design of a new compliance training program and delivery of the training in-country
• Advising the Independent Reviewer of the Connaught Review concerning the UK Financial Conduct Authority’s (FCA) supervision of the collapsed Connaught Income Fund Series 1, including conduct of the investigation and preparation of the public report.
• Investigation into alleged corrupt practices in the Brazilian and Canadian operations of a European company. Conducted remediation measures, including advising on related litigation, termination of third party contracts, and dismissal of employees, and engagement with internal stakeholders and the client’s key customers.
• Supporting an independent integrity compliance consultancy reporting to the African Development Bank (AfDB) in relation to a large Chinese company debarred by the AfDB and other MDBs.

• Listed as a key lawyer for Regulatory Investigations and Corporate Crime - Legal 500.

• BPP University Law School, GDL and LPC
• SOAS, University of London, MA
• Durham University, BA

• England and Wales
• California
• Not admitted in New York. Practicing under the supervision of firm principals.

• Member of the ABA International Anti-Corruption and International Anti-Money Laundering Committees
• Member of the International Bar Association (IBA), with interests in the Anti-Corruption Committee and the Business Human Rights Committee
• Member of the Business and Human Rights Lawyers Association 
• Member of the Young Fraud Lawyers Association
• Member of the Transparency International Professional Supporters network (TIPS)