Leon specialises in digital assets, blockchain, financial regulation, financial crime and related regulation.
His practice covers advisory and contentious matters and his clients include disruptive and emerging tech businesses, multinationals, financial institutions, corporate fiduciaries and high-net-worth individuals.
Having worked as a specialist financial crime prosecutor for the Government of Jersey in the Channel Islands and also as in-house counsel for a number of blue-chip companies, Leon is able to draw upon first-hand experience and expertise to assist clients with governance, compliance and investigatory matters.
Leon also has a keen interest in the intersection between financial crime compliance and blockchain businesses; he conducts regulatory health checks on client businesses and advises clients on the structuring and development of their crypto businesses to strike the right balance between innovation, commercial objectives and regulatory compliance.
I worked with Leon Hurd while he was at Ogier, Jersey, on a number of complicated and contentious client matters that involved compliance with the sanctions regimes. Leon’s advice was always very pragmatic and timely and I could rely on it in dealings with challenging client matters.
Mirek Gruna, IQEQ, Chief Commercial Officer, Jersey
Leon advised on structuring requirements for a decentralised OTC digital asset platform, including guidance around the regulatory regimes of offshore jurisdictions. Leon provided key strategic and regulatory advice, and his impressive knowledge and willingness to find solutions was very refreshing.
Alex Stickler, Co-Founder, DiamondSwap
Leon and I worked together a few years ago, when I was working for a global administrative services company, on a very complicated sanctions matter in a challenging offshore regulatory environment … Leon provided clear and prompt advice and his technical knowledge was outstanding.
Angelina Spunt, Head of Legal, Altum Group
Expertise
- Digital assets and blockchain
- Disruptive technology
- Financial regulation
- Financial crime & compliance
- Gaming regulation
- Dispute resolution
- Economic sanctions
- Data privacy
Experience
Digital Assets & Cryptocurrency
- Advised a cryptoasset insurance business on regulatory perimeter issues concerning the provision of crypto wallet/custodian services in accordance with the FCA registration scheme.
- Provided regulatory advice to a nifty fifty influencer concerning the structuring of NFT prize competitions and compliance with the Gambling Act.
- Advised a founder at seed phase on the development of a tokenised services platform and on the use of blockchain and fungible tokens within the platform, in addition to considering gambling laws in relation to gamified aspects of the venture.
- Advised on the development of a crypto gaming project by providing legal and regulatory advice on the minimum viable product, assisted with the preparation of the project white paper and wire frame in order for the client to engage with funders.
- Provided regulatory advice on a proposed venture to tokenise real estate for fractionalised ownership and also on the tokenising and vaulting of tangible property.
- Acted on behalf of victims of a crypto investment scheme scam, including a High Court freezing injunction against persons unknown, working closely with blockchain tracing experts and leading domestic and foreign counsel to obtain disclosure orders against a large offshore crypto exchange.
Gambling
- Advised clients on the application of ASA and CAP code rules in relation to the promotion of betting/prize competitions.
- Advised a yacht company in relation to the structuring of a prize competition to ensure that it implemented a sufficient level of skill, judgment or knowledge to place the competition outside of a licensing requirement.
- Regulatory advice to a nifty fifty blockchain influencer concerning the structuring of NFT prize competitions and compliance with the Gambling Act, including review of terms and conditions of the competition.
- Advised a founder of an online poker/NFT project in relation to compliance with the Gambling Act.
- Advised a client on the design of a cryptocurrency mining game and compliance with both FCA and Gambling Commission requirements.
- Advised a blockchain-based football trading platform as to whether crypto tokens issued by the platform constituted financial securities.
- Provided a client with advice and an international comparative analysis of gaming/gambling rules in relation to a project engaging Panama, BVI, Cayman and the UK. The project potentially involved the operation of a lottery and prize draw.
Technology
- Advised a cross-border digital commodity trading platform by providing regulatory guidance and solutions to ensure compliance while preserving the commercial proposal’s integrity.
- Advised an AI construction analytics company on whether the software that it uses to deliver services to clients could be caught within the scope of Russian sanctions.
- Advised a SAAS business operating in the ticketed events industry on regulatory compliance including guidance on the application of FCA rules, Payment Services Regulations, and Electronic Money Regulations.
- Advised the developers of an investment algorithm on legal and regulatory issues impacting on their business model.
- Advised a start-up online platform to connect investors with businesses seeking funding. Advised on the application of FCA consumer and investment regulations.
Fraud & Financial Crime
- Advised a financial institution on cross-border investigation by ACPR into their AML/financial crime controls. Provided Jersey AML compliance guidance and advised on resisting sharing confidential information with ACPR outside of established mutual assistance gateways.
- Advised a corporate administrator on a trust structure with possible proceeds of crime from a suspected Russian fraudster. Guided on SARs preparation, obtaining consents, and coordinating with foreign counsel in asset-holding jurisdictions.
- Collaborated with forensic accountants and officers during an insider trading and money laundering investigation by providing legal counsel and liaison with prosecution authorities in the UK and offshore.
- Worked on the prosecution of a financial institution for criminal failings in its money laundering systems and controls.
- Advised a bank in relation to parallel civil and criminal proceedings. Civil proceedings in Jersey concerned the bank’s refusal to pay away substantial funds, while the US criminal proceedings concerned allegations that the beneficial owners of the funds perpetrated large-scale criminal fraud in South Africa and the US.
- Advised a corporate administrator of a complex joint venture investment structure between two major countries, one of which is subject to complex sectoral economic sanctions. The structure involved a number of entities across a number of jurisdictions. Provided ongoing sanctions and AML advice on proposed transactions, in addition to responding to regulatory queries.
- Advised a bank during an investigation to ascertain whether it held funds derived from corruption in Africa. Work included advising on a potential constructive trustee application to seek directions as to what to do with the funds.
- Conducted an internal review of a fiduciary company’s compliance with risk-based systems and controls obligations arising from AML requirements, pursuant to money laundering legislation and guidance.
Financial Services
- Advised a consumer hire business on potential failings of regulatory obligations connected to the delivery of its business. Advised on engagement with the FCA and also on remediation steps to bring the business in line with regulatory expectations.
- Advised a company on whether its business fell within the scope of FCA regulated insurance activity. Advised on perimeter issues and structuring of the business.
- Advised an international financial institution on financial regulatory matters arising in relation to the migration of its banking businesses from Jersey to the Middle East. Successfully negotiated the cessation and migration of the banking business.
- Acted for a major financial institution on a section 166 skilled person regulatory investigation in respect of the sale of interest rate derivative products.
- Acted for a major financial institution on a contentious regulatory investigation into the sale (and any potential mis-selling) of mortgage products, advising on liability and redress.
Dispute Resolution
- Acted on behalf of a claimant pursuing claims under the Data Protection Act and under common law offences in relation to the misuse of her personal data and private information.
- Acted for a senior management function employee of an authorised pensions business. Successfully resisted allegations of failings of regulatory responsibilities in the context of a gross misconduct claim by the employer.
- Advised a defendant investment wealth manager in relation to claims of negligent investment advice.
- Advised a franchisee company in respect of a dispute with a multinational franchisor.
- Advised a former trustee of a substantial investment trust in relation to breach of duty claims by the incumbent trustee in respect of investments made by the trust
- Advised an Italian HNW beneficiary of a family trust in a complex dispute. The trust assets comprised an international manufacturing business and SPVs holding significant property interests in Europe. Worked with foreign counsel to coordinate legal action.
- Advised a liquidator of a Jersey company in respect of unlawful distribution clawback claims against the company’s former directors.
Recognition
Master’s degree in International Corporate Governance and Financial Regulation – received a distinction and the Best Graduating Student award
Career
Leon qualified as a solicitor in 2010. Prior to joining Keystone Law in 2023, he worked for a number of firms and businesses, including:
- Linklaters
- Eversheds
- Ogier
- Mercer
- Adecco
Leon also served as a specialist financial crime prosecutor for the Government of Jersey, Economic Crime and Confiscation Unit (ECCU).