Toby Lamarque

Full Profile

Toby’s practice involves advising multinational corporates on a wide range of financial crime risks, in areas including bribery and corruption, fraud, money laundering and sanctions.

He has extensive experience in conducting financial crime risk assessment and gap analysis exercises, developing bespoke crime prevention programmes, identifying and managing third party risks, and implementing anti-financial crime technology platforms.

Toby frequently leads complex internal investigations into financial crime allegations arising through companies’ whistleblower platforms or from other external sources. He has also supported companies in responding to external investigations by authorities including the Serious Fraud Office, National Crime Agency, Financial Conduct Authority and US Department of Justice.

In his over 10 years of work in anti-financial crime he has advised companies in sectors including engineering, agriculture, commodities trading, government, hospitality, finance, retail, media and outsourced services.

Prior to joining Clyde & Co, Toby previously worked on the US Department of Justice’s money laundering and sanctions monitorship of a major international bank and as an investigator at the UK Serious Fraud Office. He started his career as a volunteer with the US Peace Corps in Cape Verde, West Africa.

Experience

• Risk Assessment: Leading an external fraud risk assessment for a FTSE 30 multinational company operating in 35 countries following the introduction of the “Failure to Prevent Fraud” offence under the UK Economic Crime and Corporate Transparency Act 2023.
• Third Party Risk Management: Designing and implementing an end-to-end third party risk management process for a Middle Eastern Gigaproject with over USD 10bn in annual procurement spend, including due diligence screening and risk assessment of suppliers in areas including bribery, worker welfare, environment, health and safety and fraud.
• Internal Investigations: Leading an investigation for a multinational engineering company into suspected money laundering connected to the sale of a gas turbine generator to a power plant project in Kazakhstan.
• External Investigations: Working on the team of legal advisers negotiating the 11th and 12th Deferred Prosecution Agreements (DPAs) entered into by the Serious Fraud Office, the first time multiple DPAs have been approved for connected companies at the same hearing.
• Crime Prevention: Leading the team developing a comprehensive compliance programme for an international agribusiness headquartered in the UAE and operating in numerous high-risk jurisdictions, including drafting and roll-out of bespoke new policies in the areas of Anti-Bribery (including gifts and entertainment), Sanctions, Anti-Money Laundering, Fraud, Investigations, Speaking Up and Conflicts of Interest, as well as terms of reference for a new Ethics Committee.