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Gavin Costelloe

Gavin Costelloe is a member of Greenberg Traurig’s White Collar Defense & Special Investigations Practice in London. Gavin is a former lawyer and prosecutor for the UK’s Serious Fraud Office (SFO). Gavin advises companies and individuals on internal, government and regulatory investigations and compliance issues related to the UK Bribery Act, fraud, market manipulation, anti-money laundering, economic sanctions, and other serious and complex cross-jurisdictional matters. Gavin has considerable experience assisting with diligence for mergers, acquisitions, and other investments including in jurisdictions with high corruption risk.

Gavin’s practice is focused on business crime investigation, defence, compliance, and risk mitigation. This includes assisting companies with internal, government, and regulatory investigations (including those conducted by the SFO, Her Majesty’s Revenue & Customs (HMRC), the Crown Prosecution Service (CPS) and the Competition and Markets Authority (CMA)), individual defence for senior executives and compliance professionals, and devising and implementing internal training and compliance progammes.

On 10 November 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) issued a £160,000 penalty against the Bank of Scotland Plc (Bank of Scotland).
Continue Reading UK’s OFSI Imposes £160,000 Penalty on Bank of Scotland for Russia Sanctions Violations

On 8 September 2025, the UK’s Office of Financial Sanction Implementation (OFSI) published a Disclosure concerning breaches of Regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 (Regulations) by UK-registered and Financial Conduct Authority-regulated Vanquis Bank Limited (VBL). This instance offers another example of OFSI’s emphasis on encouraging organisations to establish effective, robust, and appropriate compliance procedures, systems, and controls to mitigate the risk of violations.
Continue Reading UK OFSI Enforcement Underscores Need for Effective Sanctions Screening and Controls

On 14 March 2025, the Office of Financial Sanctions Implementation (OFSI) issued a “Disclosure” against UK-registered and regulated charities for breaching Regulation 36 (6) of the Counter Terrorism (International Sanctions) (EU Exit) Regulations 2019 (the Regulations) by failing to respond to OFSI’s requests for information (RFI).
Continue Reading OFSI Takes Enforcement Action Against UK Charities

On 6 November 2024, the UK government published its long-awaited Guidance for the new offence of failure to prevent fraud (FTP Fraud Offence), which will

Continue Reading UK Failure to Prevent Fraud Offence Widens Net for Corporate Criminal Liability