Tom Hine

Consultant Partner
About
Recent Work
Expertise
Accolades

Tom is a highly experienced lawyer, specialising in financial services regulation, investigations and enforcement, and commercial law.

In regulation, Tom’s expertise covers a wide variety of financial services laws, with a particular focus on wholesale markets, including the Financial Services & Markets Act, the FCA Handbook, and UK onshored versions of MiFID II, the Benchmarks Regulation, SFTR, EMIR and the Market Abuse Regulation. He is also expert in trading venue rulebooks, including LME and ICE, as well as codes of practice such as the Precious Metals Code and the Baltic Code. In his previous in-house role at a major exchange (see below), Tom liaised frequently with regulators at the FCA and the Bank of England and defended against regulatory investigations. He has a practical understanding of the issues faced by regulated entities, which most lawyers in private practice do not.

In investigations and enforcement, Tom has a deep understanding of the investigations and enforcement process, having served as Head of Enforcement at a major regulatory body for more than 13 years. As Head of Enforcement, Tom pursued investigations and enforcement actions against banks, trading firms and other regulated and non-regulated entities, and secured millions of dollars in fines. Tom has a particular interest in the investigations and enforcement process of trading venues such as the London Metal Exchange, ICE Futures Europe Limited, the London Stock Exchange, CBOE Europe Limited, and Aquis Stock Exchange.

In commercial law, Tom has a wide range of experience in preparing, negotiating and reviewing large and small general commercial contracts, joint ventures, partnership agreements, non-disclosure agreements, IT contracts, heads of terms and market data licensing agreements. Tom is adept at focusing on the points that really matter and dealing with issues in a highly pragmatic way.

Prior to joining Acuity, Tom amassed over 20 years’ experience in law, having served in various senior positions at the London Metal Exchange (LME), including General Counsel (running a 12-strong team of lawyers), Head of Enforcement, Company Secretary, Member of the Executive Committee and Senior Management Team, Chair of the Platinum and Palladium Oversight Committee, Member of the Market Surveillance Oversight Committee and others.

During his time at the LME, Tom oversaw the acquisition of the exchange by HKEX, the building of a new clearing house, won major victories in complex litigation, pursued enforcement action against member firms and warehouses who infringed the exchange’s rules, dealt with UK and overseas regulators, and provided advice on multiple complex commercial and regulatory issues. He also wrote large parts of the exchange’s rulebook, notices and warehousing rules. Tom was an integral member of the senior management team and regularly presented highly complex issues to the board of the company in a practical and comprehensible way. His understanding of exchanges is unparalleled.

Tom has a BA and MA in history from Peterhouse, Cambridge and studied post-graduate law in Nottingham. Prior to joining the LME, Tom worked at major UK and US law firms.

 

    • Representing a finance company in respect of an FCA investigation into alleged breaches of FCA principles, conduct rules and other parts of the FCA Handbook
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    • Representing a trading firm in respect of an investigation by an exchange into alleged breaches of the exchange’s rules
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    • Advising a listed firm on MiFID II, financial promotion and benchmarks
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    • A project to design a carbon emissions trading scheme for an entity in the maritime sector
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    • A review of a trading firm’s metals trading and governance arrangements
    • A review of a trading firm’s regulated outsourcing arrangements and drafting policies and procedures
    • Re-negotiating a trading firm’s outsourcing arrangements with a major IT supplier
    • Training for several different firms on exchange rules and procedures
    • Training on FCA and exchange enforcement processes

 

  • Advising exchanges, trading firms, brokers, warehouses, fintechs, data licensors, benchmark administrators and other financial services firms
  • Particular focus on exchange-traded commodities, including metals
  • Advice on rules, policies and procedures and governance arrangements
  • Assisting exchanges and other regulators in pursuing investigations and enforcement actions, as well as with market participants to defend against enforcement actions
  • General commercial contracts, joint ventures, partnership agreements, non-disclosure agreements, IT contracts, heads of terms, market data licensing agreements
  • Drafting and reviewing articles of association, terms of reference for boards and committees, and a wide range of policies and procedures. Understanding Combined Code and the UK legislation such as the Modern Slavery Act and the Bribery Act
  • Tom has been named twice in Financial News’ “40 under 40 rising stars of the Legal Profession”
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