Cameron Crowe KC

Regulatory investigations

Cameron advises companies and directors on consumer enforcement risk, including investigations and enforcement action brought by the Competition and Markets Authority (CMA) and other regulators under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). His practice spans the full lifecycle of consumer enforcement, from early-stage investigations and strategic engagement with regulators, through to statutory notices, contested proceedings, and appeals.

He is particularly experienced in acting for businesses facing allegations of misleading pricing practices, mis-selling, aggressive commercial practices, and systemic consumer law breaches. He regularly works on matters carrying significant commercial and reputational risk.

Cameron has in-depth knowledge of the enforcement powers contained in Schedule 5 of the Consumer Rights Act 2015, having appeared in two connected appeals in the Court of Appeal concerning the scope of Schedule 5 (R v AUH [2022] EWCA Crim 1113; [2023] EWCA Crim 6).

Civil enforcement (consumer protection)

Cameron has extensive experience of civil consumer enforcement, including applications for enforcement orders and interim orders under Part 8 of the Enterprise Act 2002 (now replaced by the DMCCA), and the defence of such proceedings. His work includes:

• representing companies and their directors in CMA investigations into alleged large-scale breaches of consumer protection law;
• advising on regulatory strategy, undertakings, and compliance measures in response to enforcement action;
• acting in contempt proceedings arising from alleged breaches of enforcement orders; and
• bringing and defending judicial review proceedings challenging the decisions of regulators.

He has advised on and appeared in cases involving the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 and the Electronic Commerce Directive, including issues concerning the liability of online intermediaries.

Criminal defence (consumer protection)

Cameron regularly advises and represents companies and directors subject to criminal investigation or prosecution for alleged consumer law breaches. His defence practice includes:

• representing national retailers alleged to have engaged in misleading pricing practices, including in online retail environments;
• advising national retailers on their internal systems and the availability of due diligence defences;
• defending companies and directors facing allegations of product mislabelling; and
• advising a multinational company on the adequacy of its procedures and on the implications of legislative reform under the Economic Crime and Corporate Transparency Act.

Criminal enforcement (consumer protection)

Cameron has been instructed in some of the most complex consumer protection prosecutions of the last decade. This experience underpins his detailed understanding of how consumer enforcement cases are investigated, built, and advanced by regulators.

He is frequently instructed as leading counsel in large multi-defendant cases arising from systemic breaches of consumer protection legislation, often involving allegations of mis-selling, and dishonest or aggressive commercial practices. These cases commonly involve national or regional enforcement bodies, extensive digital and documentary evidence, complex legal argument, and lengthy trials.

Recent instructions include:

• being instructed by a National Trading Standards team to prosecute a 14-defendant conspiracy to defraud, involving appellate litigation to the Court of Appeal on the scope of Schedule 5 of the Consumer Rights Act, and listed for two three-month trials;
• prosecuting, on behalf of a Regional Trading Standards team, a series of cases concerning the dishonest and aggressive sale of goods to hundreds of vulnerable and elderly consumers;
• prosecuting illegal money lending offences under the Financial Services and Markets Act 2000; and
• prosecuting letting agents for breaches of the Consumer Protection from Unfair Trading Regulations 2008 and fraudulent trading.

Cameron’s work in life sciences and food regulation includes cases involving nutrition and health claims, vaping and e-cigarettes, novel foods, general food safety, and food fraud. His clients include national retailers as well as prosecuting authorities.

The scope of his work has included criminal prosecutions, enforcement notices, and judicial review.

Recent examples of his work include:

• Advising on judicial review of the Food Standards Agency in relation to cannabidiol (CBD) products.
• Representing a multi-national company in a case described as “precedent setting” in relation to the novel shape and advertising of alcoholic drinks.
• Defending a multi-national company for alleged misleading nutrition and health claims made in relation to a range of food supplements.
• Advising a wholesale supplier of e-cigarettes and vaping products on the application of the Tobacco and Related Products Regulations 2016.
• Prosecuting wholesale meat and fish suppliers for supplying fraudulently misdescribed and unsafe products on a national basis, thereby contaminating the food chain.

Cameron advises and represents companies and lenders in matters arising from the regulation and mis-selling of consumer financial products. His work in this area spans both civil and criminal proceedings and includes advisory work at an early stage of disputes and regulatory scrutiny.

He has particular experience in defending allegations of mis-selling and unfair relationships in claims brought under sections 75 and 140A of the Consumer Credit Act 1974, including cases arising from the financing of insurance products and renewable energy installations. He has acted in matters involving complex factual and legal issues relating to disclosure, commission structures, and the adequacy of information provided to consumers at the point of sale.