Sam Thomas

Experience & Expertise

Sam is a highly experienced and respected practitioner in the fields of Regulatory Law, Financial Crime, Inquests and Inquiries, and Cyber Law. Sam’s has a growing Police Law practice. He is ranked as a leading junior in both Chambers & Partners and The Legal 500. He was nominated as the Legal 500 Professional Discipline Junior of the Year in 2024 and 2025.

Regulatory Law

Sam is the Chair of the Association of Regulatory & Disciplinary Lawyers (ARDL), he is on the Attorney General’s Civil Advocate Panel (London B), and is a member of List B of the Specialist Regulatory Advocates in Health and Safety and Environmental Law. Sam’s primary focus is on financial regulation and he is regularly instructed by the Pensions Regulator as an appellant advocate, and by HMRC in relation to the enforcement of their anti-money laundering (AML) regulatory function. Sam also has extensive experience  in the healthcare sector in respect of disciplinary proceedings and NHS Performers List disputes. He is regularly instructed to advise and represent registrants of the General Medical Council, the General Dental Council, General Optical Council, , The UK Council for Psychotherapy, and the British Psychoanalytic Council:

Examples of his recent exemplary work in this field include:

• The Pensions Regulator v Been Design London Ltd [2026] UKUT 88 (AAC) – instructed by the Pension Regulator to ensure the enforcement of a sanction following a failure to meet the requirements of a Compliance Notice. The Upper Tribunal provided general guidance for the First Tier Tribunal for future determinations.
• Singh v General Dental Council [2025] EWHC 1761 (Admin) – instructed by the GDC following an appeal by the Registrant that a finding of dishonesty would have been undermined by evidence heard in an interim order hearing. The High Court determined that the material which was potentially available to the Council at first instance, but was not known by presenting counsel, could have undermined the finding of dishonesty.
• Pandian v General Medical Council [2024] EWHC 629 (Admin) – instructed by the MDDUS to appeal a determination of dishonesty available here. It was submitted that the Medical Practitioner Tribunal Service had not properly adopted the guidance of the Administrative Court in Dutta [2020] EWHC 1974 (Admin) and Khan [2021] EWHC 374 (Admin). The case received particular press coverage on the basis of ongoing concern that ethnic minority doctors are being treated differently within the regulatory system, including by the British Medical Journal and iNews.
• Phillip Freeman Mobile Welders Ltd v Pensions Regulator [2022] UKUT 62 (AAC) – instructed by the Pensions Regulator in a case concerning whether deemed service of a compliance notice was an irrebuttable presumption.

Financial Crime, Financial Regulation and Civil Fraud

Sam is well-placed to provide continuity of counsel to his clients due to his overlapping expertise in regulatory, civil and criminal law. He has particular expertise in defending high-profile allegations of dishonesty and money laundering cases, often with an international aspect, and has appeared in complex confiscation and cash forfeiture hearings in both a civil and criminal context. Sam regularly provides representation and advise, including the preparation of pleadings, in claims and defence of fraud in a civil claim. Sam was involved in the success defence of a party alleged to have contributed to a multi-billion pound carousel fraud perpetrated against the Danish Tax Authority.

Sam writes extensively in relation to anti-money laundering regulation and guidance. He was the Specialist Advisor to the House of Lords Select Committee in relation to the Fraud Act 2006 and Digital Fraud, and contributed to the final report, available here. In addition, he was a contributory editor of Simon’s Taxes, the leading reference service on UK direct tax, in 2021-2022.

Examples of his recent work include:

• Skatteforvaltningen (The Danish Customs and Tax Administration) -and- Solo Capital Partners [2025] EWHC 2364 (Comm) – instructed by Penningtons Manches Cooper to draft the Defence for the sixth and seventh defendants in what has been recognised as one of the most complex and high value (£1.4 bn) set of proceedings to come before the Commercial Court. Mr Justice Andrew Baker dismissed the claims by the Danish Tax Authority in respect of what it claimed was a fraud perpetrated against it via a cum-ex trading model used by defendants around the world.
• R v Bartholomew [2025] EWCA Crim 1129 – instructed by the Pensions Regulator to respond to an appeal against sentence following a conviction for an offence contrary to section 77(5) of the Pensions Act 2004. This is now a leading authority in relation to sentencing criminal offences under the Pensions Act 2004.
• R v Armstrong (2025) – leading counsel for the second defendant who was alleged to have engaged in a sophisticated blackmail perpetrated by an armed gang that deployed anti-surveillance techniques to seek to avoid a dynamic police investigation.
• R v AK & X (2021) – leading counsel for the second defendant, X, a child accused and ultimately acquitted of computer misuse offences and blackmail. The case received significant coverage in the international press, including by the BBC and Reuters.

Inquests and Inquiries

Sam has a developed practice in inquests and inquiries. He acted as Junior Disclosure Counsel for the Solicitor to the Hillsborough Inquest, the Independent Inquiry into Child Sexual Abuse, and various investigations by HMRC and the Department of Justice. He is familiar with issues of data protection and legal professional privilege in this jurisdiction and abroad.

More broadly, Sam has represented individuals, companies and insurers at inquests, particularly Article 2 inquests touching on the Health and Safety at Work Act 1974.

Recent work:

• Re: Rochelle Crane (2025) – Ms Crane was killed by a loosened brick-slip following Storm Eunice. The Jury determined that the building developer, who instructed Sam, held no blame for the death.

Police Law

Sam’s Police Law practice has grown from his successful criminal defence of officers accused of violence, sexual offending and misconduct in a public office. He has been instructed by the Police Federation, through Penningtons Manches Cooper, to represent serving officers in the High Court and the Court of Appeal. Since joining Chambers Sam’s Police Practice has continued to grow.

Examples of his recent work include:

• Norman v Adler & Wilkinson [2023] EWCA Civ 875 – represented the defendant police officers in this significant Court of Appeal case concerning the law of contempt of court. Sam’s submissions were adopted by Thurwell LJ in her leading judgment. Please click here for press coverage by the New Law Journal. Live coverage was recorded because of the importance of the hearing, available here.

Cyber Security

Sam is the author of Cyber Security: Law and Practice (LexisNexis, 2nd Ed., 2019), Blockchain and Cryptocurrency: International Legal and Regulatory Challenges (Bloomsbury, 2nd Ed., 2023), as well as numerous articles for Counsel Magazine on cyber security and cyber resilience. He is also an elected member of the Bar Council Information Technology Panel. He has a wealth of knowledge in relation to the criminal, civil, and regulatory aspects of cyber law, including:

• Information management and personal data breaches
• Data handling, including transfer overseas
• Cryptocurrency
• Blockchain and Non-Fungible Tokens (NFTs)
• Employment disputes and the misuse of confidential information

Recommendations

“Sam Thomas is a very accomplished performer. He is always well prepared and has a nicely understated style.”
Chambers & Partners

“Sam goes above and beyond for us. He’s always very accurate and provides excellent support.”
Chambers & Partners

“Working with Sam is easy. He’s highly knowledgeable, approachable, and has the ability to foresee issues and arguments early on and provide detailed, sound advice.”
Chambers & Partners

“A very hard-working, sensible, pragmatic barrister and a safe pair of hands.”
Chambers & Partners

“His skill and knowledge within criminal law is vast.”
The Legal 500

“He is able to provide specialised feedback on criminal matters – understanding the criminal nuances that may affect each case.”
The Legal 500

“Sam goes above and beyond to understand the needs of the client, and his knowledge and experience means he provides excellent advice and case presentation.”
The Legal 500

“Sam’s ability to guide clients through complex issues is one of his greatest strengths. His advocacy is excellent, and he deals with serious matters against leading counsel with comfort and ease.”
The Legal 500

“One of his greatest strengths is his advocacy skills. He is both articulate and persuasive and his delivery is accurately pitched to suit the tribunal he is addressing.”
The Legal 500

Publications

• Cyber Security: Law and Practice (LexisNexis, 3^rd, 2026), available here
• Blockchain and Cryptocurrency: International Legal and Regulatory Challenges (Bloomsbury, 2^nd, 2023), available here
• Sam was the contributory editor of a chapter on anti-money laundering and regulatory oversight for Simon’s Taxes (LexisNexis), 2021-2022
• Sam has written numerous articles for Counsel Magazine on cyber security and cyber resilience, all of which you can find here

Memberships

• Chair of the Association of Regulatory & Disciplinary Lawyers (ARDL)
• Elected member of the Bar Council, as well as the Bar Council Information Technology Panel
• Fraud Lawyers’ Association

Privacy

Sam adopts and adheres to the provisions of his privacy policy which can be found here.

Further Information

For further details of Sam’s practice please contact a member of the clerking or client service team.

Bar Council Membership No: 58933
Registered Name: Sam Thomas
VAT Registration No:  154834889