Overview
Zoe Osborne's practice focuses on cross-border financial crime and contentious regulatory investigations and litigation. She has represented numerous clients in investigations by the Serious Fraud Office (SFO) and the Financial Conduct Authority, as well as in internal investigations, and investigations and defense work before other agencies and regulators in the UK and worldwide. Zoe has a breadth of experience across sectors, jurisdictions and enforcement agencies, and is regularly involved in advising on crisis management issues, including cyber security.
Clients have sought Zoe's advice and counsel in matters involving allegations of bribery, fraud, money laundering, and other financial crimes. Most recently, she advised the Board of Serco in connection with a criminal investigation by the SFO into allegations of fraud and false accounting and negotiated only the fifth Deferred Prosecution Agreement in the UK.
Supplementing her deep skillfulness in investigations, Zoe brings a wealth of financial services contentious regulatory and compliance experience gained during secondments with Citigroup and Barclays and while in private practice. She has represented institutions and individuals in relation to regulatory issues including market abuse, systems and controls failings, and breaches of regulatory requirements. She also has undertaken investigations for financial institutions involving the wholesale foreign exchange market, credit default swaps, government bonds and sovereigns, supranationals, and agencies bonds (SSAs).
- Solicitor, England & Wales
- L.P.C., Nottingham Law School
- LL.B., University of Birmingham
Areas of Work
Representative Matters
White Collar Crime/Contentious Regulatory
- Represented the Board of Serco in relation to criminal investigations into fraud and accounting fraud, crisis management and risk process emerging from the scandal concerning the performance of electronic monitoring contracts for the UK government, including assisting Serco to investigate the issues, liaising with the UUK SFO and, ultimately, negotiating a deferred prosecution agreement (DPA).
- Represented a global investment bank in relation to the global criminal and regulatory investigations relating to the manipulation of LIBOR and the foreign exchange markets.
- Represented a corporate client in connection with investigations by the SFO, US Department of Justice (DOJ) and other law enforcement agencies related to bribery allegations.
- Represented a global investment bank in connection with criminal raids by HMRC and other global law enforcement agencies and the follow-on investigations.
- Represented a global public telecommunications company in connection with allegations of fraud.
- Represented a listed company in connection with allegations of fraud against hundreds of thousands of customers and investigations by Trading Standards and the SFO.
- Advised a major UK-incorporated financial institution on global financial sanctions and anti-money laundering regulations.
- Represented a major bank in investigations by regulators into potential violations of US financial sanctions.
- Represented the private equity arm of a multinational financial institution on financial crimes issues, including drafting amendments to its anti-money laundering, sanctions, and anti-bribery policies.
Litigation/Arbitration
- Represented a global news organization in connection with civil claims arising out of a criminal prosecution.
- Represented a multinational investment bank in proceedings in Jersey related to breach of trust.
Speaking Engagements
- "Different Approaches to Monitorships and Post-Resolution Compliance Requirements," GIR Live: Women in Investigations Conference, September 23, 2021
- Managing Regulatory and Enforcement Risks: Preparing for the Impact of COVID-19, The Legal Week's Dispute Resolution Forum, June 16, 2021
- "Which Agencies Should Be Keeping You Awake at Night?," GIR Interactive: Europe, December 8, 2020
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"Anti-Corruption Case Review: The The Extra-Territorial Reach of the FCPA, the UKBA and Recent Expectations of Corporate Compliance Programmes," C5's 6th Annual Conference on Anti-Corruption Nordics, Oslo, Norway, January 28, 2020
News & Publications
Media Mentions
May 2, 2024
Client Alerts
Criminal Enforcement and Investigations: Key Considerations in the EU and the UK in 2024
January 22, 2024
By: Zoe Osborne
Client Alerts
ESG and Sustainability: Key Considerations in the EU and the UK in 2024
January 22, 2024
By: Ruxandra Cana, Eva Monard, Eléonore Mullier, Alexandra Melia, Zoe Osborne, Byron Maniatis
Client Alerts
Regulatory Landscape in the EU and the UK: Key Considerations in 2024
January 22, 2024
By: Renato Antonini, Eva Monard, Byron Maniatis, Yongqing Bao, Elli Zachari, Ruxandra Cana, Eléonore Mullier, Alexandra Melia, Zoe Osborne, Guy Soussan, Anne-Gabrielle Haie, Maria Avramidou, Charles Whiddington, Yumiko Takahashi, Zanda Romata, Darren Abrahams, Tom Gillett, Roman Spangenberg, Jonathon Egerton-Peters, Michael Lee
Steptoe Investigations & Enforcement Blog
The Introduction of the U.K. "Failure to Prevent Fraud" into Law
October 31, 2023
By: Zoe Osborne
Press Releases
Seven Steptoe Lawyers and the Real Estate Practice Recognized in Chambers UK 2024
October 19, 2023
Press Releases
Steptoe Receives Seven Practice Rankings, Seven Individual Awards in The Legal 500 UK 2024
October 4, 2023
Media Mentions
Law360 Quotes Zoe Osborne on Parliamentary Test for UK Serious Fraud Office's New Powers
September 4, 2023
Media Mentions
Law360 Quotes Zoe Osborne on the UK Serious Fraud Office's Decade-Long Probe into Mining Company
August 31, 2023
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Lucinda A. Low, Rachel B. Peck, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jingchun (Cherry) Huang, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Lucinda A. Low, Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Rachel B. Peck, Jefferson Klocke, Veronica Ganzitti, Jingchun (Cherry) Huang, Troy Shephard, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
European Public Prosecutor to Take EU Finance Fraudsters to Task?
April 28, 2020
By: Zoe Osborne
Client Alerts
Considerations for Conducting Internal Investigations Remotely
March 30, 2020
By: Patrick F. Linehan, Zoe Osborne, Katherine M. Dubyak, Jefferson Klocke
Client Alerts
FinCEN Penalizes Compliance Officer for Anti-Money Laundering Failures
March 24, 2020
By: Zoe Osborne, Jack R. Hayes
Client Alerts
UK Serious Fraud Office Case Update: The Elusive 'Directing Mind and Will'
March 6, 2020
By: Zoe Osborne
Client Alerts
FCPA/Anti-Corruption Developments: 2019 Year in Review
January 21, 2020
By: Lucinda A. Low, Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Ali Burney, Fernando Q. Merino, Rachel B. Peck, Alexandra Baj, Jefferson Klocke, Veronica Ganzitti, Troy Shephard, Lin Yang, Bo Yue
Events
Webinars
Quarterly Investigations & Enforcement Update Webinar
May 1, 2024
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
January 25, 2024
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Lucinda A. Low, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
October 19, 2023
Speakers: Andrew C. Adams, Jason Abel, Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, John J. Kavanagh, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 27, 2023
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Cáitrín McKiernan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
April 27, 2023
Speakers: Jason Abel, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
January 26, 2023
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Coy Garrison, Patrick F. Linehan, Lucinda A. Low, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 28, 2022
Speakers: Jason Abel, Iris E. Bennett, Amba M. Datta, Coy Garrison, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
April 21, 2022
Speakers: Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Paul R. Hurst, Lucinda A. Low, Alexandra Melia, Michael Campion Miller, Wendy Wysong, Rachel B. Peck
Webinars
Investigations & Enforcement Webinar Series
January 27, 2022
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Paul R. Hurst, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Noteworthy
- Best Lawyers in the United Kingdom, Fraud (2024)
- Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists from Around the World" (2021)
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Chambers UK, Financial Crime: Corporates in London (Firms) (2020-2024)
- Legal 500 UK, "Leading Lawyer," Regulatory Investigations and Corporate Crime (2021-2024)
- Legal 500 UK, "Next-Generation Partner," Fraud: White-Collar Crime (2021-2024)
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Legal 500 UK, "Next-Generation Partner," Regulatory Investigations and Corporate Crime (2019)
Professional Affiliations
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The Fraud Lawyers Association