Anita Clifford

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“Anita is one of the strongest barristers there is in the anti-money laundering space. She is a leading junior and is enormously respected amongst the AML specialists in the City.”
Legal 500 (2024)
“Straightforward, very responsive and really smart.”
Chambers UK (2023)
“Well respected in the market, she has a busy practice and publishes academically on the subject.”
Chambers UK (2023)
“Anita is absolutely fantastic – she is extremely knowledgeable and responsive, in addition to being very confident. Her advice is implicitly trusted because it is to-the-point, confident and prompt. Highly recommended.”
Legal 500 (2023)
“Anita is very hard-working and publishes a lot of articles looking at this area of the law.”
Chambers UK (2022)
“A fantastic rising star who is knowledgeable and reassuring in the delivery of her advice.”
Chambers UK (2021)
“Anita is helpful, diligent and quick to respond.”
Chambers UK (2021)
“An impressive performer.”
Legal 500 (2021)

Personal profile

Anita Clifford is highly approachable and ranked in the Legal 500 and Chambers UK for Money Laundering & Proceeds of Crime work, where she has been described as a fantastic rising star who is knowledgeable and reassuring in the delivery of her advice.

Anita defends and prosecutes across the range of Chambers’ practice area. She has a particularly busy defence practice spanning serious drugs, firearms and violent offences.

Alongside her general Crime practice, Anita has a strong financial crime practice. She prosecutes and defends serious frauds and money laundering offences. She also regularly advises law firms and companies on anti-money laundering investigations and regulatory requirements, suspicious activity reporting and account freezing under Part 5 of the Proceeds of Crime Act 2002. She also advises on the United Kingdom’s financial Sanctions regime. Anita is interested in the interplay between human rights and proceeds of crime and is part of the counsel team in the significant case of R (World Uyghur Congress) v Home Secretary, HMRC and NCA [2023] EWHC 88 which is the first case to consider proceeds of crime in the context of supply chains affected by forced labour. Anita is also currently instructed by Peters and Peters in relation to the Post Office ‘Horizon’ independent public statutory Inquiry.

Instructed by the Council of Europe, she has undertaken anti-money laundering and anti-corruption projects in Georgia, Moldova, Czech Republic and Serbia. She has also contributed to anti-corruption workshops in Kenya and Zambia with the African Union.

Originally from Australia, Anita qualified after a year as a Judge’s Associate in the Supreme Court of Queensland. She was a solicitor from 2011 in private and government practice, with her early years spent at a prominent criminal and human rights firm, defending vulnerable clients and gaining exposure to death in custody Inquests.

Anita is a contributor to the Lloyd’s Law Reports: Financial Crime and co-author of a book on the Criminal Finances Act 2017 with Jonathan Fisher QC.

She has been appointed to the Legal Action Committee of an NGO, Global Legal Action Network (GLAN) and supports several mentoring programmes aimed at diversity amongst aspiring barristers.

Recommendations

Anita is one of the strongest barristers there is in the anti-money laundering space. She is a leading junior and is enormously respected amongst the AML specialists in the City.

― Legal 500 (2024)

Straightforward, very responsive and really smart.

― Chambers UK (2023)

Well respected in the market, she has a busy practice and publishes academically on the subject.

― Chambers UK (2023)

Anita is absolutely fantastic – she is extremely knowledgeable and responsive, in addition to being very confident. Her advice is implicitly trusted because it is to-the-point, confident and prompt. Highly recommended.

― Legal 500 (2023)

Anita is very hard-working and publishes a lot of articles looking at this area of the law.

― Chambers UK (2022)

A fantastic rising star who is knowledgeable and reassuring in the delivery of her advice.

― Chambers UK (2021)

Anita is helpful, diligent and quick to respond.

― Chambers UK (2021)

An impressive performer.

― Legal 500 (2021)

Crime

Anita defends and prosecutes general Crime cases and is a CPS Panel Advocate (Grade 2). She is well placed to deal with vulnerable defendants and witnesses and, when defending, carefully considers the scope for representations to be made at an early stage.

Represented defendant at trial of six serious offences of violence, including intentional strangulation. Self defence was raised and the case involved cross-examination of a witness with an intermediary. The jury acquitted him of all six offences (2023, Maidstone Crown Court)
Represented defendant who pleaded guilty to repeat drug supply offences. The court was persuaded to impose a suspended sentence notwithstanding the timing of the repeat offending (2023, Isleworth Crown Court).
Instructed to defend in multi handed conspiracy trial pertaining to the sale of Encrochat phones (ongoing, Luton Crown Court, led)
Represented defendant charged with possession with intent to supply cocaine and money laundering. The defendant gave a prepared statement and no comment interview, was located with drugs and significant quantities of cash and had refused to provide PINs to two phones. He was unanimously acquitted of both counts (Southwark Crown Court, 2023).
R v DG (2023) – Anita Clifford, led by Paul Jackson secured unanimous not guilty verdicts for a male charged with conspiracy and possession of 18 firearms and ammunition for sale/transfer. The complex, multi-handed, serious organised crime trial was a prosecution led by the NCA following a long and thorough investigation which included the use of covert surveillance. The 6-week trial included complex disclosure issues and expert evidence on firearm functionality and classification as well as mobile phone data. Paul and Anita were instructed by Lee Barton at Paul Martin and Co Solicitors.

She also has experience with Private Prosecutions, having previously been a senior associate at a private prosecution firm in London.

Represented the defendant at trial of affray, alongside a co-defendant. The Crown case was that weapons had been used, including a concrete post and bottle. A paramedic present for the incident was a Crown witness. A submission of no case to answer was made and a verdict of acquittal was directed at the close of the Crown’s case (Kingston Crown Court, 2023).
Represented a vulnerable defendant with history of like offences on a charge of assaulting an emergency worker. Advice was provided on the need for an expert psychological report to support the defendant’s case of self defence and requests for disclosure of footage of the incident was pressed. Following service of the report the Crown offered no evidence (Luton Crown Court, 2023).
Instructed to represent the second defendant on a charge of attempted murder or in the alternative wounding with intent. On day 2 of the jury trial, the matter resolved with the Crown accepting the defendant’s plea to a lesser offence of wounding in the absence of intent (Maidstone Crown Court, 2023).
Defended a single count of assault occasioning bodily harm. The Crown case was that it was vigilante justice resulting in serious injuries to the complainant. Self defence was raised and the defendant was unanimously acquitted after a jury trial (Nightingale Court, 2022).
Defended a single count of threatening with a large knife in circumstances where there was CCTV footage of the incident which occurred on a busy high street and the Crown called independent eye witnesses. The defendant raised self defence and was unanimously acquitted after a jury trial (Harrow Crown Court, 2022).
R v W (2022) – Instructed to represent a defendant accused of assault bodily harm. At trial three eyewitnesses to the altercation gave evidence. He was acquitted after a Crown Court trial.
R v B (2022) – Instructed to represent a defendant with no prior convictions facing trial for two counts of assault of an emergency worker. Following detailed representations, the prosecution offered no evidence on one count, on the day of trial, and the defendant received a caution for the remaining matter, obviating the need for a trial.
R v G (2022) – Instructed to represent a youth defendant charged with Class A possession with intent to supply, alongside an adult co-defendant. A Section 45 Modern Slavery Act defence was raised and the prosecution offered no evidence the week before the Crown Court trial, following representations.
R v C (2022) – Instructed to represent a defendant charged with careless driving in circumstances where, if convicted, they would face a loss of licence. There was CCTV of the collision. The defendant was acquitted at trial.
R v B (2021) – Instructed to represent a defendant accused of assault bodily harm where the allegation was use of his car as a weapon causing injury and there was an independent eye witness. He was acquitted after trial.
Re X (2021) – Instructed to defend pre-charge following a racially aggravated incident and make detailed representations. No charges were brought.
R v D (2020) – Instructed to prosecute driving offences resulting in injury to a third-party, requiring cross-examination of experts. Resulted in conviction after a three-day trial.
R v Y (2021) – Instructed to prosecute a multi-handed youth robbery turning on identification. Resulted in conviction after a two-day trial.

Proceeds of Crime and Confiscation

Anita has appeared in civil and criminal cases involving allegations of Fraud and money laundering. She is currently instructed on a high profile judicial review where she has been granted a leave application with underlying POCA issues.She regularly defends and prosecutes fraud and money laundering cases in the Crown Court.

Anita is appointed to Level 2 on the CPS specialist POCA panel.

She has advised on a wide range of POCA issues, including on high value and sensitive matters led by Jonathan Fisher KC. She also advised on several individuals, firms and companies as sole counsel on anti-money laundering, asset forfeiture and other POCA matters.

R v U (2023, Guildford Crown Court) – Instructed to defend historical carbon credit fraud involving detailed consideration of financial transactions and expert evidence.
R v K (2023, Harrow Crown Court) – Instructed to defend a bounce back loan fraud which related to grossly inflated turnover. The defendant pleaded guilty and the court was persuaded to impose a suspended sentence.
R v S (2022, Southwark Crown Court) – Instructed to defend drug-related money laundering in circumstances where large amount of cash was found, the defendant was unanimously acquitted of all offences.
HMRC v X (2022, Nottingham Magistrates’ Court) – Instructed by the respondent company to defend high value account freezing order involving allegations of fraud and money laundering failures.
R v U and others (2021) – Instructed to represent a former employee who pleaded guilty to fraud by abusing his position of trust, together with three others, and persuaded the court to impose a suspended sentence.
Re E (2021) – Instructed to lodge a complaint to the Financial Ombudsman following termination of a bank account for POCA concerns.
Re F (2020) – Instructed by a venture capitalist firm to challenge a bank account freeze in place for several months. Following detailed representations the freeze was lifted within three weeks of being instructed.
Police v C (2019) – Instructed to defend the respondent to an account forfeiture application relating to circa £100,000. Following detailed representations the application was withdrawn on the day of hearing.
NCA v S and N (2019) – Instructed (led) to appeal a cash forfeiture order turning on the use of an unregistered money service business and Hawala banking. Appeal allowed and the Court took an exceptional step of ordering costs against the NCA.
R v C (2018, led) – Instructed to defend a banker in a multi-handed fraud trial. Evidence was led of unauthorised customer account access and the defendant was acquitted.

Financial Services Regulation

Anita is experienced in Financial Services Regulation cases.

Instructed to advise regulated advisory business in relation to alleged anti money laundering breaches investigated by HMRC and an account freezing order under Part 5 Proceeds of Crime Act 2002 (ongoing).
Instructed to advise regulated firm in relation to failure to register business for anti money laundering supervision, including advice on dealings with HMRC (2022).
Re E (2021) – Instructed to deliver tailored anti-corruption training to a high street fashion brand with international presence and to advise on the development of a business-wide financial Sanctions policy.
Re Belarus sanctions (2021) – Instructed (led) to advise a commercial firm on the width of the new Belarus sanctions imposed by the UK and their impact on the firm’s clients and work in progress.
Re W (2021) – Instructed to advise a law firm on Suspicious Activity Reporting in the context of a high value property conveyance raising ‘red flags’.
Re Y (2021, led) – Instructed by a global regulated business to advise on and represent it in dealings with HMRC in the context of an AML investigation and complex transaction in the background.
Re O (2020) – Instructed by a trust and company services provider to advise on representing it in dealings with HMRC, within the context of the self-reporting of AML registration breach.
Re M (2020) – Instructed by a money service business to advise on and review an AML policy within the context of an HMRC investigation for alleged AML regulatory failures.
Re S (2020) – Instructed by a high value dealer to make representations to HMRC seeking review of the penalty proposed to be imposed for AML breaches. Representations resulted in a two-thirds reduction of the penalty.

Education

Bar Transfer Test, BPP University (2017)
Master of Laws, London School of Economics: Distinction (2015)
BA / LLB, University of Queensland: First Class Honours (2009)

Awards

Lionel Murphy Scholar (2014)
Commonwealth Country and Regional Students Tertiary Scholarship (2007-9)

Memberships

South Eastern Circuit
CBA
POCALA
Female Fraud Forum

Publications

‘Anti-Corruption Sanctions, The Bribery Act and Unexplained Wealth Orders’, Crim. L.R, 2022 1, p41-47, co-author
Criminal Finances Act 2017, Informa Law, 2018, co-author with Jonathan Fisher QC
Case Note: ‘Menci & Garlsson Real Estate SA and Others v. Commissione Nazionale per le Società e la Borsa (Consob) & Joined Cases Di Puma v. Consob and Consob v. Zecca (CJEU)’, International Legal Materials, 2018, 57(4), 583-615, author
‘Corporate Criminal Liability in the Supply Chain: A Coherent Divergence?’, Crim. L.R., 2018, p633-645, co-author