Expertise

Scope, depth & method

Financial and economic enforcement sits at the intersection of law, economics, and human behaviour. Our expertise covers the full span of enforcement matters, with the depth to see what a single lens would miss.

Scope

Where we operate

Our practice is based in the Netherlands, but we are regularly instructed abroad. What draws that work is expertise rather than geography:

‍- European Union. We act in Dutch matters and in matters in other European member states, including e.g. Belgium and France. Financial law is predominantly European law, and that is where our specialism lies.
- United Kingdom and Guernsey. We have acted in English and Guernsey proceedings as experts on questions of Dutch and European regulatory and criminal law arising in civil claims.
-‍ United States. We have worked with US counsel in matters before the Department ofJustice, the SEC, the CFTC and FINRA, particularly in trading and market conduct issues.

Beyond these jurisdictions we work with local counsel wherever a matter takes us.

What we work on

Market abuse is one of our core areas of expertise: disclosure violations, insider dealing, and manipulation in its various forms, from pump and dump to spoofing, and from information-based manipulation to wash trades. We have acted in market abuse matters arising in the ordinary course of business, around public bids, M&A deals and securities offerings, and in trading itself, involving shares, bonds, futures, mortgage-backed assets, tradable rights and crypto-assets.

We are also active in financial regulatory matters, dispute resolution and white collar crime. We regularly act as experts or strategic advisers in complex disputes involving overlapping fields of law and multiple jurisdictions, and as counsel: advising on strategy when a supervisor or prosecutor opens an inquiry, conducting internal investigations, and representing companies before the authorities and the courts.
 

Who we work with

We are often engaged by national and international law firms, from magic circle to specialist boutiques, when a case turns on a question of Dutch or European law, or when conduct needs to be investigated and qualified. In cross-border matters we work alongside local counsel.

We also act directly for listed and non-listed corporations, banks, market makers, investment funds and exchanges, the institutions. They come to us when an authority starts asking questions, when a transaction raises questions, or when conduct may amount to a violation. They trust us for our specialist expertise and our creative thinking.

We have also worked with regulators, prosecutors and the European Commission, which shapes how we read a case from the other side.

Areas of deep specialism

01.

Disclosure violations

When and what should a listed company disclose, enforcement actions taken when it does not, and subsequent civil claims.
02.

Insider trading

Who qualifies as an insider. When is a trade insider trading. Legitimate sharing cross a line. Front-running, market soundings.
03.

Trade-based manipulation

Pump and dump, spoofing, marking the close, wash trades. Shares, bonds, futures, mortgage-backed assets, tradable rights and crypto-assets.
04.

Information-based manipulation

Misleading corporate statements and press releases, misrepresentations in financial statements, stock price manipulation and meme stocks.
05.

Fraud, AML & bribery

Misrepresentation in financial statements, accounting fraud, AML violations, facilitation payments and bribary in public and private relationships.
06.

Crypto & digital asset crime

Crypto assets, virtual currencies, tokens and exchanges. New instruments, same principles. Complex money laundring schemes.

Expertise is not only what you know. It is how you look.

The dual lens

Neemley brings legal training, economic expertise and an understanding of emerging technologies to every matter

Comprehension

We look past the legal surface to the data, the context, the sequence of decisions that actually took place.

Creativity

We have a track record of creative solutions in matters., often overlooked by the client and other law firms.

Clarity as practice

Complex matters, clear analysis, simple solutions, and lucid communication. Whether for a court, a board, or a regulator.

Publications