Today’s Chambers Chatter stays at 4-5 Gray’s Inn Square, where associate member barrister Wendy Miller operates after representing both Cummins and Cepac against Lee Thompson. Wendy can leave the employment files alone today. We are heading into financial regulation, where the carpets are expensive, the acronyms breed after dark and a hedge-fund founder can apparently respond to an internal disciplinary committee by removing the committee and installing himself instead.
The barrister is Nikesh Pandit, called in 2010 and now a 4-5 practitioner across regulatory, professional-discipline and business-crime work. Chambers describes him as a strong advocate, an innovative thinker and, in one especially polished testimonial, a “velvet gloved fighter”. In the Crispin Odey matter, however, Pandit was not defending the man with the hedge fund and the governance problem. The FCA appointed him as an investigator. According to 4-5, he assisted with compelled interviews, supported leading counsel through the Regulatory Decisions Committee process and became a core member of the FCA team that later defended the case before the Upper Tribunal.
That is quite a brief.
Because Crispin Odey did not merely end up with a regulatory warning and a sternly worded letter. By September 2026, the Upper Tribunal had upheld a lifetime ban from financial services, found that he lacked integrity across all five allegations advanced by the FCA and settled the financial penalty at £1,529,374.
Apparently integrity now comes with VAT-adjacent pricing.
Nikesh Pandit Enters The Hedge Fund
Crispin Odey founded Odey Asset Management and became its ultimate majority owner. For years, his name belonged to the peculiar British financial caste where money becomes personality, personality becomes mythology and a sufficiently successful fund manager can begin to look less like an employee and more like weather.
Then internal discipline arrived.
In February 2021, Odey received a final written warning after an internal process concerning inappropriate behaviour towards female employees. The Upper Tribunal records that the first Executive Committee had made five categories of adverse findings involving inappropriate comments, non-consensual or unwelcome touching and harassment or bullying behaviour towards women in subordinate positions. Odey accepted those findings at the time.
That last phrase matters.
The later Upper Tribunal case did not require the judges to determine the truth of every historical sexualised-misconduct allegation afresh. Instead, the regulatory case centred on what Odey subsequently did with the governance machinery responsible for holding him accountable.
And what he did with it was fucking spectacular.
The Final Written Warning Meets Its Owner
A final written warning is supposed to convey a fairly simple institutional message: behave yourself or the next meeting may involve cardboard boxes.
Odey’s warning required professional conduct towards staff, including temporary employees. Later in 2021, concerns arose about his interactions with a temporary receptionist, and Odey Asset Management began investigating whether he had breached the warning.
The firm scheduled a second disciplinary hearing for January 2022.
This created a problem for Odey.
Not a legal problem in the ordinary sense. Not a scheduling clash or missing Teams invitation. The problem was that the Executive Committee might actually make a decision he disliked, including dismissal for gross misconduct.
The Upper Tribunal’s eventual assessment of his response was almost indecently useful to anybody writing satire. It found that his stated reasons for removing the committees reflected a “warped set of values based on a strong sense of entitlement” and that his true motivation was self-interest and self-preservation.
TCAP occasionally spends hours searching for a metaphor.
The judiciary occasionally just delivers the bastard fully assembled.
Christmas Eve At Odey Asset Management
On 24 December 2021, while normal offices were winding down and somebody somewhere was trying to remember whether the supermarket still sold cranberry sauce, Crispin Odey used his majority control to remove the first Executive Committee.
Christmas Eve.
Nothing says seasonal corporate governance like sacking the people due to decide whether you should be sacked.
He then appointed himself as the sole member of the Executive Committee.
The regulatory problem here was not especially subtle. FCA rules required at least two approved senior managers. By replacing the committee with himself, Odey put his own firm in breach of regulatory requirements.
Then came 6 January 2022, the date on which the disciplinary hearing had been scheduled.
Odey, now sitting alone as his own Executive Committee, decided that the hearing should be postponed indefinitely because he could not conduct it impartially.
You could frame that as self-awareness.
You could also frame it as setting fire to the courtroom and then observing that conditions were unsuitable for trial.
Happy Christmas, You’re Fired
The judgment supplies one detail so perfectly British that it deserves its own little glass case.
After Tim Pearey, OAM’s chief executive and one of the removed ExCo members, resigned on Christmas Eve, Odey replied accepting the resignation with sadness and wished him “Happy Christmas”.
There is etiquette, and then there is City etiquette.
Remove governing committee.
Install self.
Trigger resignation.
Season’s greetings.
Somewhere in Mayfair, a Christmas cracker just contained a redundancy consultation.
The more serious point was that the Tribunal rejected later attempts to justify the first committee’s removal as driven by genuine concerns about fairness, outside pressure or the future of the firm. Instead, it found that Odey feared the committee would not produce the result he wanted.
So he changed the committee.
Financial services governance, but with the emotional maturity of unplugging the PlayStation because your brother is winning.
Committee Two Gets A Turn
After briefly discovering that a one-man executive committee might attract regulatory attention, Odey appointed a second ExCo in January 2022 and stepped aside.
Normal governance had apparently returned.
For eleven weeks.
The second committee began preparing to deal with the disciplinary process. Meanwhile, further concerns emerged, safeguarding measures were discussed and Odey objected strongly to proposals that included working from home, taking a sabbatical or working elsewhere in the office while matters were resolved.
According to evidence accepted by the Tribunal, Odey repeatedly threatened senior colleagues with consequences if the disciplinary process proceeded in a way he disliked. Those threats included closing the business, removing directors’ and officers’ insurance and suing people personally.
The hedge fund had apparently discovered a new asset class: executive committee volatility.
On 31 March 2022, Odey removed the second ExCo as well.
Then, because apparently the first episode had not exhausted the concept, he appointed himself sole member again.
Two Committees, Same Disposal Method
This is where ordinary corporate governance begins to resemble a malfunctioning gameshow.
Committee One prepares to consider disciplinary allegations.
Committee One disappears.
Committee Two eventually takes over.
Committee Two begins moving towards the same awkward subject.
Committee Two disappears.
The majority owner returns to the big chair.
At this point you no longer need an organisational chart. You need a whiteboard, red string and perhaps a tranquiliser.
The Tribunal found that Odey would not permit either committee to proceed when he feared it might reach a result against him. It rejected his various explanations and concluded that self-preservation drove the removals.
That distinction turns the whole thing from chaotic governance into something far uglier. The committees were not being rotated because of some abstract strategic disagreement. They held responsibility for scrutinising the conduct of the man who also possessed the power to remove them.
It is difficult to hold the king accountable when the king owns the guillotine.
“Warped Set Of Values”
Tribunal judgments are generally not written for entertainment. They contain statutory frameworks, submissions, evidential analysis and paragraphs that can tranquillise cattle at twenty paces.
Then every so often the robes come off.
The Upper Tribunal said Odey’s asserted concerns reflected a “warped set of values based on a strong sense of entitlement”.
That is not the FCA press office adding spice.
That is the Tribunal.
It found that his real motivation lay in his own self-interest and self-preservation, that he repeatedly threatened to close the firm if committees dismissed him and that he substituted himself when he feared they would not decide matters in his favour.
There is regulatory criticism.
Then there is a three-member Upper Tribunal effectively telling you that your moral compass appears to have been assembled upside down.
No TCAP garnish required.
Nikesh Pandit Gets The Clipboard
By the time the FCA investigation developed, Nikesh Pandit had entered the story from the regulatory side.
4-5 says the FCA appointed him as an investigator. His work included assisting with compelled interviews and supporting leading counsel through written and oral advocacy during the FCA Regulatory Decisions Committee process. Chambers also describes him as a core part of the FCA team responding to Odey’s later Upper Tribunal proceedings.
This is where the contrast with some previous Chambers Chatter subjects becomes useful.
Pandit is not arriving to rescue a client from an embarrassing judgment. He is part of the machine producing one.
The “velvet gloved fighter” has apparently put down the velvet and picked up the regulatory stationery.
And there was plenty to investigate.
The FCA Finds A Governance Shitshow
The FCA eventually advanced five allegations of lack of integrity.
Three went to the heart of the ExCo removals: frustrating the disciplinary process for self-interested reasons, recklessly disregarding governance and regulatory requirements, and risking the entrenchment of a culture in which inappropriate conduct towards female employees could remain unchallenged.
The remaining allegations concerned candour.
The FCA said Odey had made misleading statements to OAM, clients, investors and the regulator itself, including a false assertion while trying to obtain the FCA’s endorsement for delaying the disciplinary process.
The Upper Tribunal upheld all five.
This was not a regulator throwing twenty allegations against a wall and celebrating because two stuck.
Everything stuck.
The Committee Was Not A Suggestion Box
One of the most revealing ideas in the judgment is brutally simple: Odey appeared willing to submit to governance only while governance produced decisions he liked.
The Tribunal later concluded that he was unwilling to submit himself to the firm’s proper governing body whenever he believed that body might act against his interests. He misused his power as controller to remove the ExCos and protect himself.
That is an extraordinary description of corporate governance failure because it reduces the whole elaborate structure to its actual purpose.
A governing committee is supposed to govern.
Not applaud.
Not validate.
Not remain in office on the implicit condition that the founder likes the answer.
If the committee only survives while agreeing with the majority owner, you do not have independent governance.
You have furniture.
The Smokescreen Department
Odey advanced numerous explanations for removing the first ExCo. He raised concerns about fairness, pressure from the FCA, legal advice, the future of the firm and whether the disciplinary process had become disproportionate.
The Tribunal was unimpressed.
At one point it characterised the reasons advanced for removing the first committee as a smokescreen masking the basic reality that Odey realised he might finally be held accountable and disliked the likely result.
Again, TCAP cannot improve this.
A hedge-fund billionaire spends years surrounded by analysts, risk models, macroeconomic forecasts and people paid handsomely to identify what the market cannot see.
Then the Tribunal spots the trade immediately.
Long self-preservation.
Short accountability.
Leverage: one executive committee.
Stop loss: apparently unavailable.
The £2.925 Billion Context
The penalty calculation carries another useful dose of scale.
When assessing deterrence, the Tribunal noted that OAM’s average assets under management during the relevant period stood at £2.925 billion.
Billions under management.
A sophisticated regulated investment firm.
Senior professionals.
Compliance departments.
Lawyers.
Executive committees.
Policies.
Regulatory permissions.
All the expensive institutional architecture designed to make a financial firm behave like an institution rather than one man’s personal treehouse.
Yet the Tribunal’s findings ultimately reduce the crisis to something painfully primitive: the owner did not like being held accountable, so he used his control to remove the people trying to do it.
You can spend billions making finance complicated.
Human ego remains stubbornly fucking analogue.
Effectively Untouchable
The Tribunal found that Odey’s conduct risked entrenching a culture at OAM in which inappropriate behaviour towards female employees had become normalised or difficult to challenge.
Its language became especially sharp when considering the message his conduct sent to employees.
Whether or not Odey consciously intended that result, the Tribunal found that he sent a clear signal that he was effectively untouchable regarding complaints made against him by female employees.
There is the culture problem stripped to bare metal.
Imagine being an employee watching it unfold.
A senior man faces internal discipline.
The committee responsible for considering it gets removed.
A replacement arrives.
That committee disappears too.
The man under scrutiny repeatedly returns to the top of the governance structure.
You do not need a laminated values poster to understand the message.
The org chart has already delivered it.
The Fine Is Not The Interesting Part
The FCA initially proposed a penalty of £1.8352 million alongside the prohibition.
The Upper Tribunal ultimately reduced that financial penalty to £1,529,374, because it rejected an aggravating-factor uplift in the FCA’s calculation. Yet the reduction did not disturb the central findings. The Tribunal dismissed Odey’s reference, upheld the prohibition and concluded that he lacked integrity in all five ways alleged.
So yes, the bill came down.
Congratulations.
Only £1.529 million for the governance experience.
Somewhere, an accountant exhaled.
The important part was the lifetime ban.
The financial number bruises.
The prohibition closes the door.
Odey Takes The Stand
The case did not improve when Odey gave evidence.
The Tribunal recorded multiple areas where his account lacked credibility and conflicted with contemporaneous documents or other witnesses. It found that some explanations had emerged long after events and did not reflect what he actually believed at the time.
More strikingly, the judges found that his earlier apparent contrition about inappropriate conduct towards female employees had not endured. At the Upper Tribunal hearing, they found that he displayed no contrition or understanding of his power in the workplace and had resiled from positions that had previously helped persuade the first committee not to dismiss him.
By the conclusion, the Tribunal said he still lacked insight into why his conduct in removing the committees demonstrated a lack of integrity.
He saw himself as the victim.
Naturally.
Corporate governance had apparently attacked him by attempting to govern.
History Gets Reinvented
The FCA was even less delicate in its public summary after the decision.
It said Odey had reinvented history, portrayed himself as a victim and displayed no contrition. Therese Chambers, the FCA’s enforcement chief, said his conduct demonstrated arrogant entitlement and accused him of behaving as though the rules should not apply to him.
There are press releases that need decoding.
This was not one of them.
The regulator had apparently reached the point where euphemism was wasting electricity.
And because the Tribunal had already upheld all five allegations, the FCA was no longer describing a provisional theory. It was summarising a regulatory victory backed by 228 pages of judicial reasoning.
Pandit’s investigation had travelled a long way from the interview room.
The Third Committee Finally Gets A Shift
Eventually, a third Executive Committee took over and held the delayed disciplinary hearing in November 2022.
That committee did not dismiss Odey.
His lawyers later relied heavily on that result, arguing that it showed the earlier committees would have treated him unfairly or that his intervention had ultimately produced a legitimate outcome.
The Upper Tribunal rejected that logic.
Whatever the third ExCo later decided could not retrospectively justify Odey removing the first two committees. If anything, the Tribunal observed, confidence that he had done nothing warranting dismissal should have given him less reason to sack the bodies due to decide the question.
That is an awkward piece of common sense.
If you believe the referee will ultimately find in your favour, repeatedly firing the referee does not strengthen the argument.
It merely makes everyone wonder why you were so fucking nervous about kickoff.
The Financial Aristocrat’s Emergency Exit
There is something wonderfully primitive about the entire governance sequence.
Finance likes to describe itself through systems.
Controls.
Risk frameworks.
Oversight.
Stewardship.
Three lines of defence.
Board accountability.
Conduct culture.
All very Basel.
All very grown-up.
Then one man with enough ownership power decides that the committee investigating him is a nuisance and the whole glittering structure suddenly has the structural integrity of a gazebo in February.
The Tribunal found that Odey placed his own interests above those of the firm, staff and investors. He threatened the business with closure, removed governing committees and treated regulatory structures as obstacles whenever they interfered with his preferred outcome.
This was not Gordon Gekko.
Gekko at least respected a board meeting enough to give a speech.
4-5 Gray’s Inn Square Puts It In The Newsletter
And eventually this extraordinary saga reaches the 4-5 Gray’s Inn Square news page.
Upper Tribunal Upholds FCA Ban on Crispin Odey Following Landmark Regulatory Case.
Neat.
Professional.
Tasteful.
Chambers explains Pandit’s investigative role, notes that Raoul Colvile and Rowena Wisniewska also assisted, and mentions that The Lawyer listed the dispute among its top 20 cases of 2026.
Quite right too.
If one of your barristers helps the regulator secure a lifetime prohibition and seven-figure penalty in a major case, that belongs on the website.
But barristers’ chambers have an extraordinary ability to compress human chaos into CV material.
Years of complaints.
Internal warnings.
Two removed committees.
Threats to close the firm.
Regulatory breaches.
Compelled interviews.
Hundreds of pages of judgment.
A lifetime ban.
Then somebody in communications turns the whole bastard thing into three polished paragraphs beneath a bookshelf graphic.
Legal marketing is industrial meat processing for catastrophe.
Nothing recognisable survives except the protein.
Wendy Miller And The Financial-Regulation Department
Which brings us back to barrister Wendy Miller.
Miller operates as an associate member of 4-5 Gray’s Inn Square after representing Cummins and later Cepac against Lee Thompson in separate Employment Tribunal proceedings. She had nothing whatsoever to do with Odey, the FCA investigation or Nikesh Pandit’s work on the case.
By now, that distinction should be printed onto a brass plaque near reception.
Her function in Chambers Chatter is much simpler. After watching her work, I wanted to look closer at how the sector and her peers operate.
Since then, 4-5 has provided fabricated qualifications, client-money disciplinary findings, vexatious-litigant proposals, civil gang injunctions, a professionally embarrassed silk, a Tory tortoise and now a regulatory case where a hedge-fund founder twice removed the committees trying to discipline him.
Most chambers websites tell you how impressive the barristers are.
4-5 accidentally includes entertainment.
Nikesh Pandit And The Velvet Glove
Pandit’s own chambers profile contains an irresistible testimonial describing him as a “velvet gloved fighter”.
Normally that sort of legal-directory prose passes through the brain without leaving a footprint. It is marketing oxygen: commercial, strategic, robust, forensic, user-friendly, excellent with clients, possibly able to walk on water if instructed by Thursday.
Here, though, the phrase lands rather better.
Because the Odey case really did require regulatory pugilism beneath all that tailoring.
Compelled interviews.
Complex evidence.
FCA decision-making.
A huge Upper Tribunal trial stretching across March and May 2026.
The founder himself under cross-examination.
Hundreds of pages of findings.
Pandit’s published role was not the glamorous final flourish of leading the advocacy at trial; chambers says he formed part of the investigative and case-building machinery behind it.
The glove stayed velvet.
The paperwork did the punching.
The Regulatory Machine Eventually Wins
Financial regulation often feels glacial from the outside.
Complaints arise.
Internal investigations begin.
Lawyers arrive.
Notices issue.
Representations follow.
Tribunals loom.
Years pass.
Everyone develops more folders.
Then, eventually, the machinery reaches the end and produces a sentence.
In Odey’s case, that sentence was effectively: you lack integrity and you are out.
The Tribunal upheld the FCA’s allegations, concluded that he had put self-preservation above proper governance, found that his conduct lacked candour and held that the regulator could reasonably have no confidence that he would follow rules when those rules conflicted with his personal interests.
That is about as comprehensive a rejection as financial regulation knows how to manufacture.
The only thing missing was a complimentary tote bag.
£1.53 Million And No Receipt Required
So where does Nikesh Pandit’s Chambers Chatter entry end?
With an investigator from Wendy Miller’s chambers helping the FCA work through one of the more spectacular corporate-governance tantrums in recent financial history.
Crispin Odey faced internal discipline.
He removed the committee.
A second committee appeared.
He removed that one too.
The Tribunal later found self-preservation, entitlement, governance failures, lack of candour and a culture in which employees could reasonably see him as effectively untouchable.
The FCA banned him.
The Tribunal agreed.
The financial penalty landed at £1,529,374.
And 4-5 Gray’s Inn Square added another line to the newsletter.
No embellishment required.
No invented misconduct.
No need to tell Nikesh Pandit he has done something wrong, because on this occasion his side was carrying the regulatory mop.
TCAP simply wandered down another Wendy Miller corridor and found a billionaire hedge-fund founder repeatedly firing the people appointed to decide whether he should be fired.
You cannot improve on that.
You can only invoice it.
Lee Thompson – Founder, The Cummins Accountability Project
Sources
- Nikesh Pandit – 4-5 Gray’s Inn Square
- Upper Tribunal Upholds FCA Ban on Crispin Odey Following Landmark Regulatory Case – 4-5 Gray’s Inn Square
- Robin Crispin Odey v Financial Conduct Authority [2026] UKUT 00351 (TCC) – GOV.UK
- Upper Tribunal Upholds Crispin Odey Ban – Financial Conduct Authority
- FCA Decides To Fine And Ban Robin Crispin Odey – Financial Conduct Authority
- Wendy Miller – 4-5 Gray’s Inn Square