David's experience as a partner at AG includes the matters set out below.

Contentious financial services advice

• Advising a building society on contentious regulatory, litigation and remediation issues during its acquisition of a bank
• 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 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 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 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 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 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 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.

Public sector investigations advice

• 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

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 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 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 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 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

• French
• German
• Italian
• Dutch (Staatsexamen NT2 Programma II, 2023)

• Law Society of England and Wales