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
Compliance Week Quotes Zoe Osborne on DOJ Decision to Narrow Scope of FCPA Enforcement
June 18, 2025
Media Mentions
Law360 Quotes Zoe Osborne in Article on Serious Fraud Office Bribery Case
May 6, 2025
Investigations & Enforcement Blog
UK, France and Switzerland Announce New Task Force To Tackle International Corruption Alliance
March 31, 2025
Client Alerts
Regulatory Landscape in the EU and the UK: Key Considerations for 2025
January 16, 2025
By: Darren Abrahams, Renato Antonini, Ruxandra Cana, Anne-Gabrielle Haie, Leigh Mallon, Alexandra Melia, Eva Monard, Eléonore Mullier, Zoe Osborne, Ronan Scanlan, Guy Soussan, Charles Whiddington, Elisabethann Wright, Byron Maniatis, Yongqing Bao, Tom Gillett, Elli Zachari, Algirdas Semeta, Maria Salomé Bustos Mesa
Martina Scassini
Press Releases
Steptoe Lawyers and Real Estate Practice Recognized in Chambers UK 2025
October 17, 2024
Stepwise Risk Outlook
Increased Secondary Sanctions Risks against Iranian Oil Exporting and Financial Networks
October 15, 2024
By: Melissa B. Mahle
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2022 Year in Review
February 24, 2023
By: Iris E. Bennett
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Brigida Benitez, Zoe Osborne, Wendy Wysong, 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: Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Jefferson Klocke, 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
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: Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Ali Burney, Fernando Q. Merino, Alexandra Baj, Jefferson Klocke, Troy Shephard, Lin Yang, Bo Yue
Events
Webinars
Quarterly Investigations & Enforcement Update
April 24, 2025
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Michelle Kallen, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Policy Perspectives Roundtable - Examining the Trump Administration's FCPA Position
February 20, 2025
Speakers: Jason Abel, Iris E. Bennett, Sandra Hanna, Zoe Osborne, Claire Rajan
Webinars
Quarterly Investigations & Enforcement Update
January 28, 2025
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Gregory S. McCue, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
October 30, 2024
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Amba M. Datta, Sandra Hanna, Ryan Hayden, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
July 31, 2024
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
May 1, 2024
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Patrick F. Linehan, 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, 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, Patrick F. Linehan, 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, Patrick F. Linehan, 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, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Noteworthy
- Chambers UK, Financial Crime: Corporates in London (Firms) (2020-2025)
- Legal 500 UK, "Leading Lawyer," Regulatory Investigations and Corporate Crime (2021-2025)
- Legal 500 UK, "Next-Generation Partner," Fraud: White-Collar Crime (2021-2025)
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Legal 500 UK, "Next-Generation Partner," Regulatory Investigations and Corporate Crime (2019)
- Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists from Around the World" (2021)
- Best Lawyers in the United Kingdom, Fraud (2024, 2025)
Professional Affiliations
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The Fraud Lawyers Association