David has extensive experience in contentious regulatory work, with a particular focus on FCA and other financial services investigations. He has acted for investment banks, 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, and financial crime systems and controls (particularly anti-money laundering). His work includes advising on culture, governance, and non-financial misconduct.
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).
David is highly experienced in cross-border work, having spent time living and working in (among other places) France, Italy, and Hong Kong.
David's recent experience as a partner at AG includes the matters set out below.
Contentious financial services advice
- 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'
- 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
- Acting for two UK banks in separate investigations conducted by the Payment Systems Regulator into alleged breaches of the Interchange Fee Regulation
- Acting for a former commodities trader in an FCA investigation into allegations of trading losses being concealed by the booking of fictitious trades
- 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 part of the UK government that deals with financial services on a highly sensitive internal whistleblowing investigation
- Advising the seven founding banks on the setup of the Business Banking Resolution Service – a voluntary ombudsman service for use by small and medium sized businesses
- Acting as a strategic litigation adviser to a UK retail bank in its implementation of the FCA's new Consumer Duty rules
- Advising a trade association and a series of financial institutions on 'wider implications' complaints before the Financial Ombudsman Service, particularly with respect to alleged unfairness in standard variable rate mortgage lending
- Advising a building society on a 'lead' customer complaint to the Financial Ombudsman Service relating to membership rights in the context of a building society merger
- 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 fintech firm in a contentious FCA process seeking to restrict its business activity
- Advising a series of different firms in relation to alleged unauthorised business / breaches of the FSMA perimeter
Contentious regulatory advice to listed companies
- 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 FRC inquiries into compliance with the Corporate Governance code / associated Listing Rules
- 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
- 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 a number of energy firms in relation to matters arising out of the REMIT regulation in gas and electricity markets
- Advising a major commodities producer on its approach to alleged abuse of commodities markets by other market participants
David also works closely with AG's Corporate Governance team to provide Board and other senior management training, to help firms and their managers understand the potential consequences of non-compliance with the FCA/PRA Senior Managers and Certification Regime, UK MAR and UK listing regime.
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 financial institution on contentious regulatory and litigation issues associated with its systems and controls for compliance with Court and POCA orders
- 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 AML assurance review
- 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 specialist lender on the application of AML legislation to complex finance structures and associated remediation
- Acting for a boutique financial services advisory firm in SFO inquiries into alleged money laundering
- Advising a series of non-financial services providers (including property firms, telecoms and consumer electronics firms) on the scope and application of AML legislation to their businesses
- Advising a financial services firm in relation to alleged misuse of electoral roll data.
David is also a Deputy MLRO for Addleshaw Goddard LLP.
- 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)
"Great FCA knowledge" – Chambers and Partners, 2024
"David is a superstar; he demonstrates real depth of knowledge and the ability to apply that knowledge to help clients articulate risks and opportunities." "A real asset to have on your side" - Chambers and Partners, 2023
"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
- Dutch (Staatsexamen NT2 Programma II, 2023)
- Professional Memberships
- Law Society of England and Wales