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clerks@5pb.co.uk

020 7583 6117

Rebecca Dix

Rebecca Dix is regularly instructed in both criminal law defence and prosecution matters with a unique insight and expertise in advising clients during the investigatory and pre-charge phase of a criminal inquiry. Rebecca has advised senior executives, corporates and government clients for a range of criminal matters, including the failure to prevent fraud and bribery offences.

Rebecca is an experienced barrister in corporate criminal law, with a unique insight and expertise in fraud and corruption investigations, having been employed at top tier defence international law firms and notably at the Serious Fraud Office as the first, Associate General Counsel (Crime) having oversight over all criminal cases across the teams and departments from first inquiry until prosecution and post confiscation. During her time as an Employed Barrister Rebecca advised on eight successful deferred prosecution agreements (‘DPA’) across various industrial sectors, including the international agreement with Airbus SE, working with the French and USA authorities to secure a DPA of €3.5billion.

Rebecca regularly advises on a range of criminal matters, from assessing current and prospective corporate policies and procedures to advising on potential criminal liability for offences such as fraud, bribery, theft and general misconduct.

In Court, as a trial advocate, her practice covers a broad range of criminal law offences from high profile international corporate crime cases to money laundering, fraud, driving, theft, robbery, burglary, serious assault, false imprisonment, and drug supply offences.

Rebecca enjoys both defending and prosecuting trials to remain sharp on strategic thinking to ensure that she is able to foresee, block or respond to the arguments from her opposition.

In addition to her advisory and court work, Rebecca regularly enjoys providing in-house corporate training, for example on failure to prevent fraud and bribery offences; corporate liability and deferred prosecution agreements.

Prior to coming to the Bar, Rebecca trained in the Territorial Army in the Royal Artillery 106 Regiment as a solider for five years and enjoys keeping an active lifestyle.

In her spare time she enjoys delivering criminal law advocacy training for Bar students and newly qualified barristers and contributing to various developing trends in corporate criminal liability.

Notable cases

Defence

Fraud and Money laundering offences

Individual clients

R v X

Finance Director fraud (£700,000): Led defence junior in a fraud investigation that alleged a long running corporate fraud, where the client was accused of abusing her position as the Finance Director at a company over several years. The fraud was originally claimed to have been worth almost £1million but after securing defence expert evidence (from a close analysis of unused material) a settlement was agreed to a much lesser fraud to under £40,000, with the Crown agreeing not to pursue two criminal charges of fraud and money laundering.

R v X and eight others Blackfriars Crown Court

Conspiracy to convert: Successfully defended X accused of a large-scale conspiracy to convert criminal property. It was alleged that £1million worth of Apple Inc. gift cards had been purchased from over twenty-five fraudulent multi- jurisdictional bank accounts. After extensive legal argument the jury were directed to acquit after the Crown offered no evidence.

R v X and two others Wood Green Crown Court

Money laundering: The defendants were charged with money laundering offences for cash found during a police search. X, was a vulnerable and heavily pregnant suspect. The police evidence was robustly challenged on procedure during a voir dire and the Judge ruled that the police had breached their own Code of Conduct and procedures. The jury returned unanimous verdicts of not guilty.

R v X and others Southwark Crown Court

SFO LIBOR rigging: Led junior, for a Barclays swaps trader, alleged to have manipulated LIBOR. Prepared his defence denying any dishonesty and reviewed extensive disclosure schedules in support of that defence in preparation of section 8 legal arguments. X was later acquitted at trial.

Operation Amazon Southwark Crown Court

HMRC Carbon trading fraud (£60m): Conspiracy to defraud HMRC of £60m and money laundering offences in relation to a carbon investment scheme. Prepared the defence statement with Leading Counsel and reviewed extensive disclosure schedules and evidence to prepare the defence. Attended pre-trial hearings on disclosure and section 8 legal arguments.

Operation Hornet Southwark Crown Court

Lloyds Banking Group fraud (£254m): X, a practising solicitor at the time, was accused with others in relation to the high-profile Halifax Bank of Scotland (HBOS) conspiracy to defraud case. X was alleged to have concealed criminal property during the period of the alleged fraud and corruption. Rebecca was part of the defence team in preparing the defence statement and analysing extensive and complex disclosure schedules, in anticipation of section 8 and legal applications before trial. Appeared at pre-trial hearings with leading King’s Counsel in preparation of the trial. X was acquitted at trial.

 

Corporate clients

Technology company

Section 1 Bribery: Advising the client on any potential liability of bribing another person in order to secure contracts.

Stock listed company

Multi-jurisdictional bribery: Advised the corporate on international bribery offences, in particular in relation to payments made to secure high value contracts. International advice was provided with partners based in UAE, USA and Europe.

High fashion industry

Dawn raid advice: Advised on current compliance policies and provided a training deck on responding to a dawn raid/search warrant execution on site in a time sensitive matter.

Listed company

ABC global policy and hospitality: Reviewing and advising on anti- bribery policy measures for the corporate in particular around corporate hospitality. Reviewing global policy documents to assess risk management relevant to the industry and nature of the business to provide advice on effective ABC measures to be applied globally.

Retail company

Bribery advice: Urgent advice required for a UK company operating in Asia where alleged bribery had occurred by foreign persons not associated to the company. Virtual meetings were co-ordinated across regions with senior executives and relevant staff members to ascertain the alleged facts to be able to advise on whether any UK bribery act offences would have made the company liable.

 

General crime

Corporate clients

X Renewable Energy Plant Corporate

Whistleblower complaint: Advised the corporate during the whistleblowing investigation, in particular on strategy for the internal response team during the long-standing complaint against senior executives. Reviewed corporate whistleblower policies and applied facts of current complaint to advise on the response.

X Industrial corporate

Harassment of senior executives: Senior leadership executives had been victims of harassment by members of the public. Client advised on the strength of the case against the perpetrator and prepared advice and drafted a letter to the authorities to report the crime to prevent and deter further offending.

 

Individual clients

R v X and another Southwark Crown Court

Serious assault: Successfully defended X against a charge of assault occasioning actual bodily harm leaving the alleged victim with a permanent eye injury. Self- defence was successfully raised and the jury found X not guilty but his co-defendant, separately represented, guilty.

R v X Lincoln Crown Court

Death by dangerous driving: Led by King’s Counsel in the defence of death by dangerous driving, two pedestrians killed on a dual carriageway after the car collision. X was the owner of the car that was driven by another who was intoxicated and driving over 100 MPH. X was convicted for aiding and abetting dangerous driving.

 

Prosecution

Bribery, fraud and corruption

Individuals

Operation Sateen Oxford Crown Court

Fraud (£1m): Led junior, Rebecca prosecuted a high value confidence trick fraud trial over twelve weeks. The defendant was unanimously convicted on seven counts of fraud by false representation (contrary to Section 1 Fraud Act 2006) for orchestrating a complex web of lies that spanned four years and defrauded victims (all closely associated friends) of nearly £1 million.

The case highlights the "Catch Me If You Can" nature of modern high-level fraud. The perpetrator meticulously crafted a persona of success, claiming that he had an elite education, substantial wealth and professional expertise.

By leveraging this false identity, Mr Stafford gained access to business-astute individuals—including a high-profile former football club owner.

He was sentenced to a term of lengthy prison sentence and a Director Disqualification Order for fifteen years.

See article for an insight into this case and suggested tips to avoid being a victim of fraud.

Fraudster Neil Stafford jailed for nine years after using 'superficial charm' to steal more than £800k

 

Government clients

X- Government Department

Government fraud (£38m): Advised on a sensitive project over six months for a Government department on potential criminal and civil fraud risks, working alongside the civil team when considering breach of contract claims to provide recommended steps to mitigate any future risk of harm to the contract for services. Instructed and worked alongside a forensic investigation team to determine whether there had been fraudulent activity by their client within the company accounts spanning over ten years with a contractual value in excess of £38 million. HMG Treasury Counter Fraud principles for public contracts and government risk assessment applied.

Serious Fraud Office 2016-2022

International fraud, bribery and money laundering: Employed by the SFO, Rebecca worked across numerous investigation teams with the latter two years of her employment appointed as the first, Associate General Counsel (crime). Rebecca advised on the most- high profile and complex fraud and bribery investigations and prosecutions conducted in England. She advised on covert operation techniques (search warrants/dawn raids) securing large volumes of evidence using Section 2 powers. Rebecca managed different teams of lawyers, senior investigators and forensic accountants during a long standing and what was to become the largest global Deferred Prosecution Agreement to date (€3.5bn).

While working on the GSK and Rolls Royce investigation, Rebecca had the unique breadth of experience from interviewing witnesses using Section 2 powers to advising on prosecutorial decisions.

Given her role as AGC, Rebecca developed a particular expertise in advising on eight of the SFO’s Deferred Prosecution Agreements that primarily related to industrials in the energy, oil and gas and aerospace sectors (AMEC Foster Wheeler, G4S, Airbus, Bluu Solutions, Airline Services, Serco).

SFO and Airbus SE

Deferred prosecution agreement (€3.5 billion): Prepared the advice and summary of facts for a significant strand of the multi-jurisdictional bribery investigation that concluded by way of the largest global deferred prosecution agreement made to date, €3.5billion. Led a team of senior investigators to investigate systemic allegations of foreign bribery in connection with multi-million-dollar aircraft contracts and Section 7 failure to prevent bribery offences (Bribery Act 2010).

R v Misick and others Turks and Caicos Islands

Wide scale corruption and money laundering (c£20m): Instructed by the Foreign Commonwealth Office with leading King’s Counsel, advising on the investigation into allegations of multi-million-dollar corruption, bribery, fraud and money laundering offences against former members of the Cabinet, foreign investors and local attorneys into alleged corrupt land allocations for the development of high-end hotel resorts in the Turks and Caicos Islands.

R v Santheepan and others Central Criminal Court

Conspiracy to defraud (£300,000): Prosecuted three defendants convicted of a year- long UK wide conspiracy to defraud credit companies. The fraud was in excess of £300,000 with over 1000 transactions. All defendants pleaded guilty to charges of fraud by misrepresentation and money laundering offences.

 

Private prosecutions

X- Telecommunications listed company

Copyright: The corporate sought to investigate potential allegations of copyright offences discovered through online advertising portals where arrangements were being made to unlawfully sell their products. Advice provided on routes to pursue a private prosecution, to work alongside recommended private prosecutor solicitors.

R v X

Planning breach: Defended a client for a planning offence. Despite it being her second planning enforcement breach for the same property, the Bench was persuaded to dispense with the case by way of an absolute discharge.

X- Government department

Fly tipping: Advisory work on the possibility of securing a private prosecution for fly tipping offences.

X

Fraud – Prepared the defence for a client being privately prosecuted in what was ultimately a breach of contract dispute.

 

Proceeds of Crime, restraint and confiscation

R v Johnson Luton Crown Court

Enforcement receivership Order: advising and drafting an enforcement receivership application for the outstanding sum of the Confiscation Order made against the defendant in a theft from employee case for over £65,000.

R v Das Liverpool Crown Court

Enforcement Receivership: A scientist, convicted of using his expertise to set up an illegal vodka and whisky distillery. Instructed to seek Enforcement Receivership Order for the outstanding £312,000 Confiscation Order.

R v Noad Central Criminal Court

Confiscation Order: Instructed for the confiscation proceedings for a client convicted after trial for a £10 million boiler room fraud trading in carbon credits.

R v Salashoor

Confiscation enforcement: Instructed to enforce a £500,000 Confiscation Order made against a UK businessman convicted of illegally exporting gyrocompass navigation devices to Iran. Drafted an unusual and complicated consent order to allow for the payment of his Order.

R v Derek Joyce Dover Magistrates' Court

Confiscation enforcement: Advised the prosecution on civil remedies available for securing the payment of the outstanding £400,000 Confiscation Order after it had been ruled that it was an abuse of process to commit the defendant to prison for failing to pay his order during the requisite period of time.

 

Insolvency company act offences

R v Huntingford Chelmsford Crown Court

Instructed to prosecute insolvency offences. The defendant had continued to act as a Director for a new company without the consent of the authorities, having been disqualified. The offence was aggravated by the fact that he had continued to obtain vehicles for his business using fraudulent details.

R v Sagoo Aylesbury Crown Court

Prosecuted a Director of several companies for false accounting under the Companies Act 1985 and the failure to comply with the Insolvency Practitioners. The company was prosecuted for under £1 million of unknown bank transfers. The defendant was convicted and sentenced to a suspended term of imprisonment.

 

Professional Appointments and Memberships
  • Crown Prosecution Service Grade 3 Specialist panels for [1] Serious Economic Organised Crime and International Directorate; [2] Fraud; [3] Proceeds of Crime and Grade 3 for all general crime cases
  • Serious Fraud Office Panel barrister
  • Visiting lecturer for the Bar Course at the Inns of Court College of Advocacy
  • Governing Barrister Bencher at the Honourable Society of the Inner Temple
  • Pegasus Scholarship Trust Committee member, Inner Temple and Equality & Diversity Committee member
  • Bar Council Committee member, formerly the Elected Employed Bar representative and current member of the Equality and Diversity working group
  • Committee member for the Bar Association of Commerce Finance and Industry
  • Former member of the Territorial Army 106 Regiment, Royal Artillery Soldier.  Officer Cadet training (1997-2003) and Lance Bombardier training completed
Education
  • Bar Vocational Course, Inns of Court School of Law (very competent)
  • LLM Masters in Criminal law and the Criminal Justice System, University College London (Merit)
Scholarships and awards
Publications and articles

 

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