Anita Clifford

Overview

Anita advises and acts in all areas of corporate and financial crime, with particular expertise in fraud, money laundering, proceeds of crime (POCA) and sanctions.

Her work spans corporate investigations, high-value fraud and money laundering trials, asset recovery, account freezing and confiscation proceedings. Anita regularly advises corporates, law firms and regulated professionals on compliance and AML obligations, including Suspicious Activity Reports (SARs), internal investigations and self-reporting.

Anita is also part of the counsel team in the landmark case R (World Uyghur Congress) v Home Secretary, HMRC and NCA, the first case to test proceeds of crime legislation in the context of forced labour supply chains.

Experience

Fraud

Anita has acted in a wide range of fraud matters, including allegations of investment fraud, revenue fraud and misuse of Covid-19 “bounce back” loans. She has experience on both the defence and prosecution side of multi-defendant trials, as well as advising corporates on internal investigations. She is known for her strategic approach and ability to navigate complex financial transactions and expert accounting evidence.

Money Laundering and POCA

Appointed to the CPS specialist POCA panel, Anita is experienced in cases across all parts of the Proceeds of Crime Act 2002, including civil recovery, confiscation and criminal offences. She is well accustomed to advising in high-value and sensitive matters and has a strong track record of securing favourable outcomes in contested proceedings. She also regularly assists corporates and law firms with compliance advice, asset recovery issues, and the handling of suspicious activity reporting obligations.

Sanctions

Anita advises corporates, individuals and law firms on the UK’s sanctions regime, including its application in complex international transactions. Her experience includes advising on the scope of newly imposed sanctions, delivering compliance training to multinational companies, and contributing to litigation at the intersection of sanctions, proceeds of crime and human rights.

Environmental 

Anita has experience in environmental matters particularly where alleged financial misconduct - such as fraud and money laundering - have arisen from underlying regulatory breaches. She was instructed in an eight-week trial defending a company prosecuted by the Environmental Protection Authority. Although the case concluded with a plea to a significantly lesser offence, her involvement provided valuable insight into the complexities of environmental enforcement and the practical challenges that can arise in EPA-led prosecutions. 

Notable cases

R v B, NM & M (2025, Harrow Crown Court)
Prosecution of conspiracy to commit money laundering involving complex international transactions in the context of a Hawala-style money service business. The case involved expert evidence on Hawala, financial regulation, and cryptoassets. Convictions were secured against all three defendants.

Instructed to advise large regulated professional services firm on AML issues, internal fraud, and self-reporting to professional body supervisory following an internal investigation (2024, ongoing)

R v M & Ors (2024, Norfolk Crown Court)
Prosecution of conspiracy to defraud and money laundering involving seven defendants responsible for running an illegal business. Prepared all pre-charge advice; the case resolved with pleas of guilty from all defendants.

R v G & Ors (2024, Southwark Crown Court)
Acted as second junior defending D1, CEO of a mining company, in relation to SFO allegations of bribery.

R (World Uyghur Congress) v The National Crime Agency [2024] EWCA Civ 715
Involved in a money laundering and civil recovery case concerning proceeds of crime, modern slavery, identifiable property, and adequate consideration in the supply chain. Engaged from the outset of the POCA proceedings.

Re production order under POCA (2024, Southwark Crown Court)
Acted for respondent challenging the making of a production order under POCA in the context of an international US DOJ tax evasion investigation.

Re DX (2024)
Advised in relation to an NCA investigation of a professional person for ss. 327–329 POCA offences of money laundering. Detailed representations led to no prosecution.

Instructed to advise on AML issues relating to a £50m+ property conveyance in London (2024)

Instructed to advise on regulatory offences under medical devices and pharmaceuticals legislation, including implications for Part 7 POCA (2024)

Instructed to advise a prominent international law firm on Suspicious Activity Reporting and wider AML issues (2024, ongoing)

Instructed to advise a large regulated professional services firm on AML issues, internal fraud, and self-reporting to professional body supervisory (2024, ongoing)

R v U (2023, Guildford Crown Court)
Defended historical carbon credit fraud involving detailed financial analysis and expert evidence.

R v J (2023, Guildford Crown Court)
Defended a trader charged with historical offences of carbon credit fraud.

R v K (2023, Harrow Crown Court)
Defended a bounce back loan fraud involving inflated turnover. Persuaded the court to impose a suspended sentence following guilty plea.

R v S (2022, Southwark Crown Court)
Defended drug-related money laundering; large cash seizure. Defendant unanimously acquitted of all offences.

HMRC v X (2022, Nottingham Magistrates’ Court)
Defended a high-value account freezing order involving allegations of fraud and money laundering failures.

R v U and others (2021)
Represented a former employee who pleaded guilty to fraud by abusing his position of trust, alongside three co-defendants. Persuaded court to impose suspended sentence.

Re E (2021)
Lodged complaint to the Financial Ombudsman following termination of a bank account for POCA concerns.

Re F (2020)
Challenged a prolonged bank account freeze for a venture capital firm; freeze lifted within three weeks of representation.

Police v C (2019)
Defended an account forfeiture application relating to circa £100,000; application withdrawn on day of hearing.

NCA v S and N (2019)
Led appeal against cash forfeiture order involving unregistered money service business and Hawala banking. Appeal allowed; costs ordered against the NCA.

R v C (2018, led)
Defended a banker in a multi-handed fraud trial. Evidence of unauthorised customer account access led to acquittal.

Reviews

Chambers UK 2026: Sanctions – Band 2; POCA Work & Asset Forfeiture – Band 3; Financial Crime - Band 4

Legal 500 2026: Proceeds of crime (POCA) and asset forfeiture – Leading Junior

'Intellectually very strong and someone with judgement beyond her years. She's got everything - she's amenable, efficient and a real junior of first choice.' Chambers UK POCA Work & Asset Forfeiture (2026)

'Anita is encyclopaedic on the law and a genuine hard worker. She's very well regarded.' Chambers UK Financial Crime (2026)

'Anita has a great work ethic. She was really great and very knowledgeable. She is a renowned expert.' Chambers UK Financial Crime (2026)

'Anita Clifford is very responsive. She is prompt and technically very good. She is proactive and creative. She is totally reliable.' Chambers UK Sanctions (2026)

‘Is extremely bright but capable of distilling potentially complex legislation into clear, easy-to-understand advice. Her technical knowledge of POCA is absolutely first-class and well beyond her years of call.’ Legal 500 Proceeds of crime (POCA) and asset forfeiture (2026)

‘Anita provides clear advice dependent on key factual points, with practical steps to take.’ Chambers UK Sanctions (2025)

‘Anita is very knowledgeable about proceeds of crime. She is very smart, highly responsive and always looking for creative ways to extricate the team from problems.’ Chambers UK POCA Work & Asset Forfeiture (2025)

‘Anita is extremely knowledgeable, with a smooth approach. Working with her was an exceptional experience.’ Chambers UK Sanctions (2025)

‘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)

‘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)