Expertise

David has extensive experience in contentious regulatory work, with a particular focus on FCA and other financial services investigations.  He has acted for retail and investment banks, building societies, asset managers, insurance and private wealth management firms, and for individuals employed by them, in some of the most high profile investigations to date.  He advises on a wide range of contentious regulatory matters, but has a particular focus on market abuse, the handling of inside information, financial crime systems and controls, and anti-money laundering.  His work also includes advising on regulatory interventions / contentious supervision,  internal investigations, culture, governance, and non-financial misconduct.

David is highly experienced in cross-border work, having worked in a 'magic circle' law firm for 11 years and spent time living and working in (among other places) France, Italy, and Hong Kong.

Since moving to Addleshaw Goddard as a partner in October 2018, with a brief to grow the firm's contentious regulatory practice, David has acted in some highly sensitive and innovative new instructions and developed a strong reputation in the market ("he has been instrumental in taking the Addleshaw Goddard team from strength to strength since his arrival and has been involved in some ground-breaking work", Legal 500 2022).  He speaks regularly at industry events and regularly provides Board and other senior management training relating to the FCA/PRA Senior Managers and Certification Regime and UK MAR.

David is personally ranked in band 3 of the 2025 edition of Chambers and Partners UK, and as a Leading Partner in Legal 500 2025, for contentious financial services regulatory work.

Experience

Selected highlights of David's experience as a partner at AG are set out below.

Contentious financial services: general

  • Advising a leading bank on a major industry judicial review of the Financial Ombudsman Service in relation to the proper interpretation of the FCA’s complaint handling rules / DISP
  • Advising a leading bank (alongside AG’s Competition team) on its response to action by the FCA relating to its concurrent competition law powers
  • Advising two financial institutions on contentious regulatory matters associated with separate high profile customer account exit ('debanking') incidents
  • Advising a financial services trade association on the UK government's proposed reforms to the legal and regulatory regime in the UK concerning 'debanking', and a major UK bank on its proposed implementation of new draft 'debanking' regulations
  • Advising a building society on contentious regulatory, litigation and remediation issues during its acquisition of a bank
  • Advising the seven founding banks on the setup of the Business Banking Resolution Service
  • Acting as a strategic litigation adviser to a UK retail bank in its implementation of the FCA's Consumer Duty rules

Contentious financial services: regulatory investigations

  • Acting for a former trader in an FCA investigation into allegations of the concealment of trading losses
  • Acting for a former senior manager of a financial services firm in relation to a PRA investigation being dealt with under the Early Account Scheme
  • Acting for two UK banks in separate investigations conducted by the Payment Systems Regulator into alleged breaches of the Interchange Fee Regulation
  • Advising a major UK bank in an investigation by the Panel on Takeovers and Mergers

Contentious financial services: regulatory interventions and contentious supervision

  • Advising a number of financial institutions including authorised firms, fintechs and electronic money issuers in relation to the FCA’s use of voluntary requirements (VREQs), voluntary undertakings (VUs) and other urgent / contentious intervention measures
  • Advising a range of firms in relation to alleged unauthorised business / breaches of the FSMA perimeter, particularly with respect to consumer credit
  • Advising a major financial institution in a PRA s166 process

Contentious financial services: internal investigations and whistleblowing

  • Advising a building society on contentious regulatory matters during a Board incident involving allegations of bullying and non-financial misconduct
  • Advising an insurance firm in an internal whistleblowing investigation into non-financial misconduct, including dealing with allegations relating to the excessive consumption of alcohol and mistreatment of colleagues at work, and associated regulatory notifications and reporting
  • Advising a building society during an incident involving the alleged breach by a director of the constitution, directors' duties and the Building Societies Act 1986
  • Advising a building society in relation to alleged breaches of the Building Societies Act 1986 arising from a non-compliant loan to a director

Contentious financial services: remediation

  • Advising a building society on contentious regulatory matters associated with past customer referrals to a third party estate planning and will writing service
  • Advising a retail bank on regulatory and litigation exposure arising from a systems migration issue affecting a portfolio of business loans, including advice on associated remediation strategy
  • Advising a retail bank on remediation of an issue relating to interest calculation in mortgage lending
  • Advising a number of firms on the application of AML legislation to complex finance structures, on associated remediation work, and on resolution of a breach of the UK’s 2017 Money Laundering Regulations through HMRC’s enforcement process

Listed companies, market abuse and UK MAR

  • Advising a listed plc on UK MAR and associated contentious regulatory matters arising from an accounting controls incident that resulted in the restatement of its published accounts
  • Acting for a FTSE 100 plc in a series of internal investigations relating to the management of inside information and compliance with UK MAR, as well as associated inquiries by the FCA and Financial Reporting Council (FRC) and remediation of its internal controls
  • Acting for a listed plc in a 'twin track' FCA investigation into potential market abuse and other breaches of the UK MAR, particularly alleged delays to the disclosure of inside information
  • Advising a listed plc in FCA inquiries into the alleged unlawful disclosure of inside information and alleged improper dealing by a senior executive and a member of their family
  • Advising a FTSE 100 plc on the requirements of UK MAR during its negotiations with the authorities of a deferred prosecution agreement under the Crime and Courts Act 2013, in respect of an underlying offence of failure to prevent bribery
  • Advising a listed plc on an internal investigation into the conduct of a senior executive relating to the alleged misuse of confidential commercial information
  • Advising (with AG’s Finance Litigation team) a listed plc on a threatened claim under s90A FSMA 2000
  • Advising an AIM NOMAD on compliance with the AIM regulatory regime in a contentious environment

Financial crime and AML

  • Acting for a specialist lender in an internal investigation into allegations of bribery, corruption, breaches of AML legislation and associated FCA rules, and advising on associated FCA reporting
  • Advising a trade finance firm in FCA and HMRC inquiries into its AML systems and controls
  • Advising a major UK bank on contentious regulatory and litigation issues associated with its systems and controls for compliance with Court and POCA orders
  • Advising a major international corporate on AML controls and suspicious activity reporting in its UK finance leasing business
  • Advising a major UK financial services business on calibration and refinement of its AML controls
  • Advising the MLRO and compliance team of a fintech in relation to inquiries by FCA Supervision into controls and remediation
  • Advising a payment services provider in a dispute with a counterparty over AML customer due diligence and compliance with the UK Money Laundering Regulations
  • Advising a merchant acquirer on AML and other financial crime issues associated with its acquisition of a portfolio of customers from another payments business
  • Advising a series of specialist lenders and asset finance firms on the review and upgrade of their AML policies, procedures and controls, including carrying out multiple AML assurance reviews, and advising on investigations and remediation activity
  • Advising a series of major UK banking providers on AML regulation as part of the incorporation and launch of 'Cash Access UK Limited', a vehicle intended to help protect access to cash in the UK economy
  • Advising a financial services firm in relation to alleged misuse of electoral roll data
  • Advising a series of non-financial services providers (including numerous property firms, a major infrastructure firm, telecoms and consumer electronics firms) on the scope and application of AML legislation to their businesses and mitigation of investigation risk

David is also a Deputy MLRO for Addleshaw Goddard LLP

Energy and commodities

  • Advising a number of energy firms on the market abuse and insider dealing provisions of UK REMIT in connection with electricity and gas trading activities
  • Advising a number of leading energy firms on the application of the financial services regime and the UK REMIT regulation to their electricity trading activities, including advising on systems and control requirements in relation to algorithmic trading
  • Advising a major commodities producer on its approach to alleged abuse of commodities markets by other market participants

Other professional regulation (SRA, FRC)

  • Advising a major international law firm in relation to SRA inquiries into its compliance with AML legislation
  • Advising a major professional services firm in relation to compliance with ICAEW and FRC regulation in connection with a public inquiry
  • Advising a major listed plc the subject of a controversial report to the FCA made by its statutory auditors 

Public sector

  • Advising a public sector body on a major internal whistleblowing investigation into alleged failures in regulation, poor culture and non-compliance with internal whistleblowing policies
  • Advising a public sector body on a highly sensitive internal whistleblowing investigation concerning financial services
  • Advising a UK government department on UK MAR and its handling of inside information in the context of the award of major public contracts to a FTSE 100 plc, and separately of its restructure of part of a publicly financed industry
  • Drafting for a public sector body policies and procedures for handling inside information and compliance with UK MAR
Education
  • BPP Law School, London (Postgraduate Diploma, 2004, Legal Practice)
  • University of Cambridge (MPhil, 2003, European Studies)
  • Oxford University (BA, 2002, Law with Law Studies in Europe)
  • Université de Paris II Panthéon-Assas (2001)
Testimonials
  • "David is hugely experienced, very thoughtful and has a great attention to detail. He goes above and beyond to provide the best service, and he is very responsive." (Chambers and Partners 2025)
  • "David is very knowledgeable. His calm and measured approach instils confidence." (Chambers and Partners 2025)
  • "David is a fantastic lawyer and he is technically very strong." (Chambers and Partners 2025)
  • "David Pygott is an exceptional lawyer in this area - he is very calm, approachable and has extensive experience and expertise. He is able to navigate complex issues easily and provides commercial high quality legal advice." (L500 2025)
  • "David Pygott is one of the most practical litigators. He is a pleasure to work with and has a practical and thoughtful approach to advising his clients." (L500 2025)
  • David Pygott is clever, meticulous, thoughtful and phenomenally hard-working." (L500 2024)
  • "Great FCA knowledge" (Chambers and Partners 2024)
  • "David Pygott is excellent – careful, detail-oriented and knowledgeable." (L500 2023)
  • "David Pygott brings a huge depth of knowledge and always seeks to apply it pragmatically to the benefit of his clients." (L500 2023)
  • "David Pygott has phenomenal knowledge of financial services regulation, close attention to detail, is devoted to client service and determined to get as good a result as possible" (L500 2022)
  • "David Pygott is both extraordinarily knowledgeable about financial services regulation and extremely hard-working. He has been instrumental in taking the Addleshaw Goddard team from strength to strength since his arrival and has been involved in some ground-breaking work." (L500 2022)
Languages
  • French
  • German
  • Italian
  • Dutch (Staatsexamen NT2 Programma II, 2023)
Professional Memberships
  • Law Society of England and Wales