Aaron Stephens

• Part of cross-office team advising a global financial institution in U.S. federal antitrust and English High Court litigation alleging that foreign currency dealers conspired to manipulate the benchmark WM/Reuters currency exchange rate and FX spreads.
• Advising a global infrastructure business in the context of an investigation by the World Bank.
• Advising various senior individuals in the context of Serious Fraud Office (SFO), Financial Conduct Authority (FCA) and cross-border (DOJ, SEC) investigations into alleged bribery & corruption, market manipulation and "spoofing", and other financial crime.
• Carrying out an internal investigation for a global commodities house into allegations of fraud and corruption in an African jurisdiction.
• Advising a range of corporates regarding compliance with U.S., UK and/or EU sanctions along with colleagues in the International Trade practice, and carrying out sanctions-related investigations
• Advising an energy sector client in relation to an internal investigation into fraudulent and misleading practices affecting an Asian project, including with regard to self reporting obligations and remediation.
• Conducting an urgent internal investigation for a global asset management firm and advising on remedial steps and notification issues.
• Assisting a major, global corporation to design and implement a new compliance department, including the drafting of all compliance policies and procedures and related staff training.
• Successfully defended various individuals in the context of the US and UK investigations into manipulation of the London Interbank Offered Rate (LIBOR) and the foreign exchange (FX) market.
• Advised MS Amlin in the context of an investigation by Lloyd’s of London, achieving a successful outcome.
• Represented Sir Paul Judge in the context of both the on-going SFO investigation into Eurasian Natural Resources Corporation, and related civil litigation in the High Court of England & Wales.
• Advising numerous corporates and financial services firms regarding compliance with the FCPA, Bribery Act 2010, anti-money laundering legislation and related financial crime compliance issues, including carrying out internal investigations in this regard.

Aaron Stephens is an English and US-qualified partner representing financial institutions, major corporate clients and senior individuals in highly sensitive litigation and investigations involving the full scope of financial and economic crime, market abuse and fraud.

Aaron has advised clients on diverse matters across Europe, North America, Asia, the Middle East and Africa in the banking/financial services, energy, defence, construction & engineering and retail industries. He has a particular focus on anti-corruption, anti-money laundering, market abuse and fraud, and with commentators saying that \"Aaron has been highly knowledgeable, pragmatic and responsive\" and \"brings real expertise to the field\" (Chambers UK 2026), \"Aaron Stephens is hugely likeable, very focused and always available\" (Legal 500 2024), that \"he has a strong financial services practice and brings infectious enthusiasm to every case\" (Legal 500 2024), that \"he understands complex matters and finds practical solutions ... he is brilliant, a responsive and reassuring person to have on your side\" (Chambers UK 2020), and that he is \"very easy to communicate with and finds solutions to complex problems\" (Chambers UK 2022).  In addition, Global Investigations Review has described him as an “excellent lawyer who is credited by sources for his work developing [his] practice into a formidable offering.”  

Aaron has carried out regulatory and white collar investigations and/or defended clients in relation to the UK’s Financial Conduct Authority (FCA), Serious Fraud Office (SFO), National Crime Agency (NCA), Takeover Panel and Lloyd’s of London, as well as in matters involving the U.S. Department of Justice (DOJ), Federal Bureau of Investigation (FBI), Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC).  He also engages in civil litigation in the English courts, and advises a wide range of corporate clients on risk management and compliance issues.