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Polly Sprenger

Partner

England & Wales

020 3319 3700

polly.sprenger@keystonelaw.co.uk

“Polly was able to identify the key drivers and stumbling blocks, and make the possible and the probable paths ahead clear.”

- Global GC International travel booking platform

Polly is a partner specialising in private prosecutions and corporate crime. She advises corporates, boards, and senior executives on internal and cross-border investigations, regulatory matters, and parallel civil and criminal litigation.

Her experience includes investigations into fraud, bribery, corruption and money laundering, as well as production, disclosure and freezing orders, civil recovery and asset tracing, and the evidential considerations of conducting internal investigations.

Polly also advises corporate clients on allegations of sexual offences in the workplace, extending to reputational risk management and crisis planning, preparedness, and response.

Expertise

Polly advises clients on complex fraud investigations, asset tracing and recovery, and cross-border financial crime matters, including the misappropriation of assets by individuals in positions of trust, fraud prevention, false accounting, and liaison with domestic and international law enforcement.

Experience

  • Investigated and liaised with law enforcement in relation to an attempted $100m fraud by a telecoms start-up days before a facility drawdown, then led cross-border asset tracing of a $45m investor debt in the US.
  • Investigated an £18m invoicing and false accounting fraud against a major budget hotel chain by a third-party supplier in administration, supporting a parallel Nottingham Police investigation.
  • Investigated the suspected misappropriation of approximately £25m of charitable funds by trustees, reporting to the Charity Commission and SFO and pursuing High Court proceedings to restore the assets.
  • Identified a fraudster operating under a false identity with a previous serious conviction overseas, liaising with UK and overseas law enforcement on remediation and prosecution strategy.
  • Defended a company director privately prosecuted for fraud by abuse of position by his former business partner following the insolvency of their construction business, who was alleged to have removed funds belonging to his partner’s family.
  • Defended a former media company director in relation to two bitcoin deposits into his wallet that UK police alleged were obtained through fraud, successfully recovering the funds and obtaining costs orders against the CPS.
  • Advised insurance brokers representing pension savers on the prospects of a private prosecution arising from a £70m cross-border insurance bond investment fraud.

Polly advises individuals, businesses, and organisations on private prosecutions arising from complex fraud, financial crime, and misconduct. She is one of the UK’s longest-standing and most widely recognised specialists in the field, with over a decade of dedicated instructions, and coordinates parallel civil and criminal proceedings, asset recovery strategies, and cross-border investigations across multiple jurisdictions.

Experience

  • Conducted a private prosecution of a multi-million-pound fraudulent investment scheme on behalf of a high-profile family, with parallel asset-tracing and criminal proceedings in the US, Germany, and the UAE, resulting in 13 convictions at Southwark Crown Court in February 2026.
  • Privately prosecuted a defendant for fraud by abuse of position and perverting the course of justice arising out of the affairs of an elderly architect with dementia, with linked proceedings in France.
  • Conducted a lengthy review of hundreds of historical private prosecutions over several years, applying the Hamilton/Post Office unsafe-conviction test and the Post Office (Horizon System) Offences Act 2024.
  • Advised a political action group on potential criminal charges arising from historic financial and other misconduct by a public figure.
  • Defended a company director privately prosecuted for fraud by abuse of position by his former business partner following the insolvency of their construction business.
  • Advised insurance brokers representing pension savers on the prospect of a private prosecution arising from a £70m cross-border insurance bond investment fraud.

Polly advises corporates, charities and senior executives on engagement with the Serious Fraud Office, drawing on her previous service as Head of Strategic Intelligence at the SFO.

Experience

  • Represented the finance director of a large multinational charged with fraudulent accounting.
  • Liaised with the SFO in relation to the investigation of a £290m fraud by directors of a media company on multiple financial institutions in the asset-backed lending industry. Conducted the initial investigation and reports to law enforcement, supported the appointed administrators through SFO enforcement action, and continued to advise on ongoing production orders and information requests during the SFO investigation.
  • Investigated the suspected misappropriation of charitable funds by trustees, reporting to the Charity Commission and SFO, and pursuing High Court proceedings to restore the assets.

Polly advises clients on internal investigations, regulatory risk, and asset recovery in matters involving bribery and corruption allegations, often with cross-border elements. She has acted for multinational pharmaceutical and energy companies, as well as individuals, on complex cross-border matters involving bribery allegations, restraint orders, and corporate transactions.

Experience

  • Conducted an internal investigation for a multinational retail chain into employee and contractor misconduct and bribery across a 2,500-store refit programme, supporting a parallel West Yorkshire Police investigation.
  • Was junior counsel in the prosecution of News of the World journalists and employees, a case centred on payments to public officials and phone hacking.
  • Advised the seller on historic bribery allegations in connection with a £60m transaction.
  • Conducted investigations into suspected bribery within the Middle East subsidiaries of a global pharmaceutical company.
  • Advised an oil company and its principal in relation to the discharge of a restraint order over assets alleged to have been used as a bribe.

Polly advises corporates, financial institutions and individuals on the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017, including restraint and confiscation proceedings, asset recovery, suspicious activity reporting obligations, and engagement with UK and overseas enforcement authorities on money laundering investigations.

Experience

  • Obtained and executed restraint orders under s.41 POCA in multiple private prosecutions on behalf of victims of high-value frauds.
  • Secured the discharge of a CPS restraint order over a former media company director’s bitcoin wallet (BTC 91.1, c.£7.5m) and continued to defend him in the related criminal investigation into the source of the underlying cryptocurrency deposits.
  • Supported a major budget hotel chain in connection with a Nottingham Police fraud, money laundering, forgery, and false accounting investigation into a third-party supplier and its directors, following an internal investigation that identified £18m of inflated and fabricated invoices.
  • Advised the interim CFO, board, lenders, and administrators of a telecoms start-up on preventing a $100m fraudulent facility drawdown, working with US counsel to obtain disclosure and freezing orders over bank accounts located in the United States and liaising with the SFO and City of London Police.

Polly advises financial institutions, corporates, and senior executives on investigations, regulatory matters, and litigation relating to fraud, bribery, money laundering, and other financial crime risks, often involving cross-border elements.

Experience

  • Advised insurance brokers representing pension savers on the prospects of a private prosecution arising from a £70m cross-border insurance bond investment fraud affecting expat victims in Spain, Portugal, and Thailand.
  • Secured the discharge of a CPS restraint order over a former media company director’s bitcoin wallet (BTC 91.1, c.£7.5m) and continued to defend him in the related criminal investigation.
  • Identified a fraudster operating under a false identity who had deceived multiple insurance companies into placing him in positions of high responsibility with access to vulnerable individuals, liaising with UK and overseas law enforcement.
  • Instructed by investment banks to conduct an investigation and take subsequent action, including liaising with law enforcement, in relation to a $100 million fraudulent drawdown of a funding facility.
  • Liaised with the SFO in relation to the investigation of a £290m fraud by directors of a media company on multiple financial institutions in the asset-backed lending industry. Conducted the initial investigation and reports to law enforcement, supported the appointed administrators through SFO enforcement action, and continued to advise on ongoing production orders and information requests during the SFO investigation.

Please note: The experience list above may include examples of work completed prior to joining Keystone Law.

Recognition

Recognised by Chambers UK for Financial Crime: Private Prosecutions (London) 2019–2026

Recognised by The Legal 500 as a Leading Partner for Regulatory investigations and corporate crime (advice to corporates) 2026

Recognised by The Legal 500 as a Leading Partner for Private Prosecutions 2026

Recommended by The Legal 500 for Civil fraud 2026

Recognised by Global Investigation Review in its directory of the top 100 women practising globally in investigations 2015

Founding member of the Private Prosecutors’ Association (PPA)

Member of the Proceeds of Crime Lawyers Association (POCLA)

Member of the Fraud Lawyers Association (FLA)

Former Certified Fraud Examiner through Association of Certified Fraud Examiners (ACFE)

“Polly is an exceptional lawyer … always professional and calm when under pressure.”

Chambers UK 2026

Polly qualified as a Barrister in 2012. Prior to joining Keystone Law in 2026, she worked at the following firms:

  •  Addleshaw Goddard
  •  Katten Muchin Rosenman UK
  •  Eversheds Sutherland