Gaon Hart

Gaon Hart

Global Anti-Bribery & Corruption Policy & Education Lead


Gaon is the Global Anti-Bribery & Corruption Policy and Education Lead for HSBC Bank. He currently advises on all aspects of the bribery & corruption Legal & Regulatory environment in over 70 countries, Global policy development and the global education strategy, focussing on compliance with the UK Bribery Act, the US Foreign Corrupt Practices Act and the Hong Kong Prevention of Bribery Ordinance, amongst other key International legislative requirements.

Gaon was formerly a Senior Crown Advocate for the Special Crime and Counter Terrorism Division of the Crown Prosecution Service (CPS). He has obtained both barrister and solicitor rights in the UK, enabling him to hold adversarial rights in all levels of criminal courts as well as being experienced in leading investigations and case progression. He was the CPS’s lead specialist prosecutor in bribery & public corruption and, due to his advisory role, was asked to undertake the first prosecution under the UK Bribery Act. He also provided training to the UK police forces in the Bribery Act.

As a specialist in white collar crime and corporate offending, Gaon has also reviewed and prosecuted cases relating to e-crime, International misconduct, Misconduct in Public Office, Corporate Manslaughter, Corporate fraud and various aligned offences (including Health and Safety). He is also experienced in prosecuting general complex and serious offending and has proven capabilities gained from investigating and conducting some of the highest profile prosecutions in the UK.

As the first lawyer working on developing the Fraud Prosecution Group and the Prosecution Team Leader he has also worked with the UK Government on fraud projects and was the lead project Lawyer, acting directly for two Attorney Generals, on the Plea Negotiations Guidelines in Serious and Complex Fraud Cases (the forerunner of DPA arrangements), while also working to develop the UK’s current counter-Fraud architecture during the 2007 Fraud Review.

Prior to working as a prosecutor, Gaon was the Associate Director of a post-graduate University Law Department (London Guildhall University) and a Principal Lecturer.

Notable cases:

  • Undertook the first Bribery Act 2010 prosecution in the UK which led to a successful conviction against a court clerk (Munir Patel).  Gaon conducted much of the advocacy himself and also led the correlated investigations into a commercial organisation and the Proceeds of Crime offences;
  • Directed a four year investigation and prosecution, leading to a Health and Safety conviction against the largest company in the world by capita (Esso Petroleum) on a corporate manslaughter indictment with another international maintenance company;
  • Coordinated the international investigation into a cross-border, bio-terrorism threat between the UK, FBI and South African police. This led to a successful conviction of the perpetrator in South Africa;
  • Prosecuted and obtained a conviction against the most senior police officer convicted of corruption in the UK; Commander Ali Dizaei;
  • Acted as advocate in one of the first legal arguments under the R –v- Blackburn principle (conviction primarily based on hearsay evidence) in a gang related murder prosecution. His successful argument to the court that sole and decisive hearsay evidence should be relied on, led to the plea by the defendant and a 30 year sentence.
  • Prosecuted numerous internet e-crime offences including one of the original internet trolls, Frank Zimmerman, who used twitter to threaten the MP Louise Mensch; and the Head of the ‘Welsh Liberation Organisation’ who used their internet site to threaten the Prince of Wales;
  • Prosecuted a multi-million pound fraud investigation against five banks which led to the conviction of numerous members of the gang (Operation Nail);
  • Acted on a pro bono basis as solicitor for a disabled individual leading to, what is believed to be, the first successful Judicial Review under the Equality Act 2010;
  • Acted as prosecutor in a multi-million pound international cocaine importation and production organised crime gang; leading to the successful conviction of 17 members of the organisation (Operation Bella Vista);
  • CPS representative to the Azelle Rodney Public Inquiry and CPS lawyer to the Middle Market Drugs Project (HM Customs and Met project) during their establishment.