Jonathan Carlos
Partner
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Jonathan has been a specialist criminal law adviser to individuals, companies, and other organisations for the past twenty years. His experience over that time has given him a broad and deep understanding of all areas relating to criminal law. His expertise is recognised by the market and reflected in the directories.
His practice comprises representation in all areas of white collar and business crime including health and safety and environmental crime, as well as a wide variety of other criminal law matters with a particular emphasis on cases with an international aspect. He is also one of a small number of solicitors with experience advising on war crimes investigations and related matters.
He provides clear strategic advice from the earliest stages – often before any formal investigation is open. He is experienced in responding to enforcement action undertaken by a range of agencies and in conducting internal investigations. He regularly works alongside colleagues at Hanidel Jones LLP specialising in other disciplines to ensure the provision of the best possible advice in relation to all aspects of a matter such as reputation management, employment and commercial advice
White collar crime and business crime
Jonathan acts for individuals and organisations in a wide range of cases involving allegations of financial wrongdoing and other forms of misconduct.
He has extensive experience advising individuals and organisations at every stage of investigations. He has attended a large number of interviews of many different kinds. These have included voluntary and compulsory interviews of witnesses and interviews under caution of those suspected of criminal offences. He has defended prosecutions brought by SFO, FCA, HMRC, CMA, NCA and the police. He routinely co-counsels with lawyers from other jurisdictions in cross-border matters.
Jonathan is frequently appointed to act as Independent Legal Advisor (ILA) to individuals in the course of investigations by their employers or regulators. In particular he has acted for many bank and other financial services employees in relation to various investigations, including those involving Libor, Forex and CumEx.
Jonathan regularly acts for organisations that come into contact with various criminal law issues. This can include advising on such things as the response to production orders or similar requests, dealing with employees accused of crime, or managing threats to the business arising from protest or other activity.
Jonathan conducts internal investigations on behalf of companies and other organisations. He understands the legal and practical challenges of such work and provides clear guidance on all aspects. He is particularly interested in the use of advances in technology in providing cost and other benefits. He recognises the importance of ensuring that investigations are well structured and focussed and that they report on time and within budget.
Proceeds of Crime (money laundering) and Sanctions advice
Jonathan has particular expertise in the area of proceeds of crime (money laundering). He advises on a range of issues including the making of suspicious activity reports (SARs). Clients include legal and other regulated professional individuals and organisations. Recent advice has included consideration of investments in crypto assets. Jonathan also advises on the impact of sanctions designations in a range of different contexts. Jonathan is the Hanidel Jones LLP’s Money Laundering Nominated Officer (MLNO).
He regularly advises individuals and organisations on law enforcement applications that seek to freeze or seize assets, including Account Freezing Orders, Restraint Orders, and other applications made under the Proceeds of Crime Act (POCA) and has been involved in some of the highest value such cases.
Health and Safety and Corporate Manslaughter
Jonathan represents companies and individuals during the initial police and Health and Safety Executive investigation, through to the conclusion of cases at inquests or in the criminal courts. He has acted in cases investigated by the Environment Agency, Fire and Rescue Authorities, the Marine and Coastguard Agency, the Civil Aviation Authority and Air Accident Investigation Branch.
Cross border matters and international crime
Many of Jonathan’s cases have a cross border element. These include investigations conducted in multiple jurisdictions, the use of mutual legal assistance and other forms of international co-operation, as well as extradition and INTERPOL Notices.
In addition Jonathan provides advice and representation in respect of war crimes and related allegations, including universal jurisdiction matters – allegations which can be investigated and prosecuted in the UK even if neither the alleged offence nor those involved have any connection with the UK. He is past Co-Chair and Advisory Board Member of the IBA War Crimes Committee.
Jonathan joined Hanidel Jones LLP in 2002 and became a partner in 2010.
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Notable cases
White collar and business crime – Individuals
- Advising in-house lawyer in CMA matter
- Providing money laundering advice to investors in cryptocurrency
- Advising lawyer in relation to HMRC investigation
- Representation of individual in CumEx related investigation
- Advising CFO in relation to HMRC investigation
- Representing in-house accountant in FCA prosecution relating to financial irregularities in publicly listed company
- Representation of solicitor in money laundering investigation
- Representing employee of construction firm in CMA investigation
- Representing finance director in SFO investigation into government contracts
- Representation of individuals in NCA cash seizure and Account Freezing Order matters
- Representing former MD of oil company in relation to Brazilian corruption investigation
- Representation of foreign politician in NCA corruption investigation
- Representation of employee of company in compelled interview conducted by the SFO
- Representation of bank employee in overseas investigation into market manipulation
- Representation of bank employee in HMRC investigation of historic film scheme
- Representation of in-house lawyer in SFO corruption investigation
- Representation of bank employees in compelled interviews conducted by the SFO
- Representation of employee in SFO compelled interview (using POCA powers)
- Representation of judge in offences against public justice matter
- Representation of fund managers in compelled interviews conducted by the FCA
- Representation of multiple bank employees in FX investigation
- Representation of bank employee in Mutual Legal Assistance request from overseas jurisdiction
- Representation of employee of insurance company in investigation by the Information Commissioner’s Office (ICO)
White collar and business crime – Organisations
- Advising a large family owned business on allegations of misfeasance
- Advising insolvency practice on its AML obligations
- Advising company on its response to direct action protests
- Advising law firm in relation to data breach allegations including conducting an internal investigation
- Advising law firm in its response to an Account Freezing Order
- Advising international charity and conducting internal investigation in relation to misconduct allegations including conducting an international investigation covering multiple jurisdictions
- Advising company wishing to deal with frozen asset
- Advising auction company in relation to AML and POCA matters
- Representation of newspaper in relation to criminal allegation including conducting an internal investigation
- Advising a company on its AML and other reporting obligations upon discovery of suspected employee wrongdoing
- Advising businesses and individuals on their reporting and other obligations under UK AML law
Health and Safety and other Regulators
- Advising construction business in HSE investigation following a fall from height
- Advising a hotel in its response to an enforcement notice
- Representation of waste business on alleged permitting breaches
- Representation of prison officer in police investigation following prison death
- Representation of international construction vehicle manufacturing company following serious accident
- Representation of business owner in large Trading Standards prosecution (including successful challenge to the imposition of a restraint order)
- Representation of farmer in animal welfare case
- Representation of international engineering company following accident in which four people died
- Representation of numerous employees in various HSE investigations into fatal and non-fatal accidents
- Representing the “Responsible Person” (under fire regulations) following large fire in retail premises
- Representation of Chairman and FD of recycling company facing allegations of breaches of environmental law (includes financial restraint proceedings)
- Representing owner of a hotel in investigation into alleged breaches of fire safety regulations following a fire
International Criminal Law
- Representation of Colonel Kumar Lama, a Colonel in the Nepalese army on charges of torture, following his arrest in the UK
- Advising various individuals on risk of prosecution in UK for war crimes and related allegations
Other
- Representation of numerous individuals facing general criminal allegations including sexual offences and violence (including murder)
- Advising individual facing allegations of humanitarian people smuggling
- Advising a school in relation to allegations made against head master
- Representation of soldiers facing allegations arising from various historic fatal incidents