Anna Keighley

Anna Keighley specialises in financial crime and its proceeds particularly, bribery, corruption, fraud and asset recovery.

She appears in the criminal and civil courts in such cases.

Proceeds of Crime

Anna represents prosecutors, foreign governments, defendants, receivers and third parties in proceeds of crime litigation in the High Court and Crown Court.

She is regularly instructed as specialist counsel by the Proceeds of Crime Unit of the CPS and others in restraint, confiscation, variations, enforcement and receivership proceedings, under POCA, CJA and DTA, and in Judicial Review proceedings.

Examples include:

> R v Jones (2018) - application to vary High Court restraint order to enforce civil judgment and impact on related, concurrent, Crown Court confiscation proceedings.

> R (on the application of O’Connell) v Westminster Magistrates Court, 2017 EWHC 3120 (Admin); 2018 Lloyd's Rep. F.C. 130 - Judicial Review of activation of default sentence on grounds of abuse of process and Human Rights violation.

> R v Brewer (2017) - Court of Appeal ruling on effect of amended S.11 POCA on ‘time to pay’ confiscation order.

   > R v F (2016) - long running litigation relating to interplay of applications to increase available amount and accumulative confiscation orders.

> R v Esfandmodz (2015) - contested High Court receivership with multiple third-party interests and associated civil claim for fraudulent misrepresentation.

> R v Gurr (2015) - multiple third-party property interest litigation in receivership application.

> Op Segman (2014) - enforcement of confiscation order in Netherland Antilles with 'corporate veil' issues.

> Op Numerator (2014) - contested Crown Court receivership in relation to third-party interests in domestic and overseas properties.

> Re T (2014) - generic advice in relation to pensions in light of Government proposals as proceeds of crime and associated tax implications.

> Re B (2014) - DTA High Court confiscation order increase.

> R v Azad (2010-2012) - settling a £2m confiscation order and various issues thereafter including enforcement following the death of the defendant.

She has also advised on numerous incoming and outgoing letters of request (for the obtaining of evidence abroad) and extradition proceedings.

Financial Crime

Currently, she is instructed by the Foreign Office's SIPT in the prosecution of attorneys and former government ministers of the Turks and Caicos Islands for £100m plus bribery, corruption and money laundering (R v Misick and others). This is a long running and complex case following a Commission of Inquiry and the suspension of the Government.

She was instructed in the prosecution of British attorneys in the Turks and Caicos Islands for Stamp Duty fraud in a $28 million dollar property transaction between U.S. nationals (R v Kerr and O'Sullivan).

Anna has also been instructed in civil fraud proceedings - intervening in civil proprietary claim connected with High Court freezing order proceedings and resisting orders which compete with criminal asset recovery.

She has been involved in CPS prosecutions for the most serious organised crime for many years.

Examples include R v Evans (2006) (£40m ostrich farm fraud and drug trafficking), R v Hoffman-Balmer (2008) (importation of £1.6m heroin woven into Afghan rugs) and R v Nightingale (2008) (importation of £35m cannabis in photocopying paper boxes).

She is appointed to the Serious Fraud Office prosecution panel and specialist proceeds of crime panel.


Regularly instructed in the area of legal professional privilege. She advises parties on applicability and waiver of privilege.

She acts as independent counsel to identify material protected by legal professional privilege whether present during the search or reviewing large amounts of seized material - as in Operation Steamroller (a £70m share sale fraud) for the Serious Fraud Office.

She also advises firms on their regulatory responsibilities, and liability under the Bribery Act 2010.

Lecturing and Publications

She both gives and organises lectures at home and abroad with an emphasis on the proceeds of crime, the professional development of others and well-being.

She is also a contributing author to 'Fraud: Law, Practice and Procedure' published by LexisNexis Butterworths.

Additional Details

In 2010, she was seconded for 9 months to the Proceeds of Crime Unit, CPS, responsible for complex, high value proceeds of crime cases in the Court of Appeal, High Court and Crown Court.   

Professional Memberships

  •         Proceeds of Crime Lawyers Association
  •         Female Fraud Forum – Education Committee Member
  •         South Eastern Circuit
  •         Criminal Bar Association
  •         Middle Temple


  • Ombudsman at the Financial Ombudsman Service

Further Professional Experience

  • Trained work-place Mediator