
Anna Keighley
Anna Keighley is a leading expert in the recovery of criminal assets, with a specialised focus on proceeds of crime arising from financial and organised crime. Her practice spans both national and international legal landscapes, providing expert counsel in complex cases involving serious financial crime, civil fraud, and asset recovery.
With a strong reputation for her work in criminal, civil, and appellate courts, Anna regularly acts as counsel for key agencies such as the CPS and SFO. She is also a trusted advisor and advocate in restraint, confiscation, variation, enforcement, and receivership proceedings under the Proceeds of Crime Act 2002 (POCA), the Criminal Justice Act 1988 (CJA), and the Drug Trafficking Act 1994 (DTA). Additionally, she represents clients in judicial review proceedings related to proceeds of crime.
Anna is frequently instructed by a diverse range of clients, including prosecutors, foreign governments, defendants, receivers, and third parties in high-stakes litigation. She is also a specialist appointed Counsel for the CPS and the SFO in the field of proceeds of crime and has earned recognition for her niche expertise. Her extensive experience also includes intervening in civil fraud and family proceedings and representing clients in proprietary claims.
A respected contributor to legal scholarship, Anna is a contributing author to Mitchell Taylor and Talbot on Confiscation and the Proceeds of Crime (Sweet & Maxwell) and has lectured on proceeds of crime law both in the UK and internationally, contributes to the Home Office development in this field of law and formerly ran education events for the Female Fraud Forum.
She is frequently called upon to offer legal insights and strategic guidance in complex legal matters, including those involving disclosure and legal professional privilege. Anna has advised on issues of privilege and waiver including as on-site LPP counsel and in cases involving large-scale document reviews, such as Operation Steamroller, a £70m share sale fraud investigated by the SFO.
From 2015 to 2020, Anna served as a Financial Ombudsman, resolving and making legally binding decision in complex banking and credit disputes.
With a career marked by high-level legal expertise, a track record of successful outcomes, and a commitment to upholding the integrity of the law, Anna Keighley is one of the leading figures in proceeds of crime litigation, trusted by clients and agencies alike for her comprehensive legal acumen and strategic counsel.
Testimonials
"Anna Keighley is absolutely delightful and a specialist in money laundering and POCA. She knows everything about the subject."
Chambers and Partners 2025
"Anna has real expertise and breadth of knowledge in POCA and not purely on the back of criminal cases: she is a POCA specialist. Her written submissions are to the point, sensible and correct."
Chambers and Partners 2025
"She is really on top of her game and fights tooth and nail for her client, leaving opponents bruised and battered."
Chambers and Partners 2025
"Anna has an encyclopaedic knowledge of confiscation and proceeds of crime matters. She is thoughtful, fair and assertive."
Legal 500 2025
"Her tremendous wealth of knowledge and work ethic impress."
Chambers and Partners 2024
"A pleasure to be against, she's a clear, comprehensible advocate who is always very tough to beat. Her advocacy is exactly how you'd teach it: smooth but to the point."
Chambers & Partners
"Anna is knowledgeable, diligent, exceptionally hardworking with superb people skills. Anna provides good practical advice and direction."
Legal 500 2024
‘A superb POCA lawyer. Brilliant on the law. Defends and prosecutes with equal alacrity. Has some significant higher court cases to her name. A star.‘
Legal 500 2023
"She knows POCA inside out and provides very good, practical advice."
"Anna is excellent with difficult clients."
Chambers & Partners 2023
"Anna Keighley is a financial crime specialist who continues to demonstrate a burgeoning practice in the proceeds of crime. She regularly advises on asset forfeiture and confiscation orders and has appeared before the High Court and Court of Appeal."
Chambers & Partners 2023
Ranked In
Cases
Asset Forfeiture & Confiscation
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, SFO and others in restraint, confiscation, variations, enforcement and receivership proceedings, under POCA, CJA and DTA, and in Judicial Review proceedings.
- Re Nixon [2020] 1 WLUK 118 – High Court application for certificate of increase under the DTA 1994; court had jurisdiction with regard to legitimately and subsequently acquired assets.
- R v Goodman (2019) – £1.6m confiscation order; issues of adverse effect of previous confiscation orders and treatment of ‘debts’ between drug dealers.
- R v Anderson (2019) – s.22 POCA application on the use and limits of R v Waya [2013] 1 AC 294 and ‘capping’ effect of R v Cole [2018] EWCA Crim 888.
- Operation Jade (2019) – multi-million £ confiscation and dispute on correct application of R v Ahmad & Fields [2014] UKSC 36.
- For multiple Member States of the EU applications to recognise overseas Restraint Orders (2019).
- 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. Defendant extradited following activation of default on a European Arrest Warrant. Successful grounds in opposition to appeal to Supreme Court.
- 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.
Bribery & Corruption
Anna 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 also advises firms on their regulatory responsibilities and liability under the Bribery Act 2010
Fraud & Financial Crime
Anna’s core practice invariably either involves or arises out of financial crime. In addition to the above examples include:
Defrauding regulatory authority (2019) – accusation of male fides of the Crown and complex PII issues.
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.
R v O’Sullivan and Kerr – instructed disclosure counsel 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.
She is appointed to the Serious Fraud Office prosecution panel and specialist proceeds of crime panel.
LPP
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 (of homes or solicitors offices) or reviewing large amounts of seized material – as in Operation Steamroller (a £70m share sale fraud) for the Serious Fraud Office.
Professional Memberships
- Proceeds of Crime Lawyers Association
- Female Fraud Forum – Standing Committee Member
- South Eastern Circuit
- Criminal Bar Association
- Middle Temple
- Grade 2 CPS Counsel
Awards, Qualifications & Other
- Appointments: Ombudsman at the Financial Ombudsman Service in the areas of banking and credit.
- Visiting Lecturer: University of Law, Bloomsbury, London delivering training in criminal litigation and advocacy.
- Trained Mediator: through London School of Mediation for ADR in civil litigation and, previously, in work-place mediation.
- Anna also experienced the role of ‘instructing solicitor’ in 2010-2011 when seconded to the Proceeds of Crime Unit, CPS, responsible for the running and conduct of complex, high value proceeds of crime cases in the Court of Appeal, High Court and Crown Court.