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Graham Thompson

Aliya G. Allen

Aliya G. Allen



  • Corporate, Commercial & Securities
  • Private Clients, Trusts & Estates
  • Banking & Finance
  • Banking & Finance
  • Corporate, Commercial & Securities
  • Private Clients, Trusts & Estates

WSG Practice Industries



Aliya Allen is a Partner in the firm’s Financial Services, Private Client, Trusts and Estates Practice Groups. Aliya re-joined Graham Thompson in February 2016, following four years as CEO and Executive Director of the Bahamas Financial Services Board.

Aliya’s practice is primarily focused in banking, investment funds, securities, securitisation and capital markets, technology, FinTech, blockchain and digital assets and regulatory matters such as FATCA, CRS, AML/CFT. She has played a leading role in the development and revision of industry defining legislation including the Investment Funds Act, 2019, the Investment Condominium (ICON) Act and in crafting and promoting policy initiatives on FinTech, Blockchain and digital assets.

Recent engagements  include:

  • Advising a global investment manager on the impact of economic substance requirements on its operations.
  • Acting for a global bank in a large-scale independent AML/CFT compliance audit.
  • Acting for a global bank with AUM in excess of $300 million undertaking a significant regulatory and compliance audit for the purposes of a global compliance project.
  • Acting for a syndicate of lenders in a $100 million facility to a utility company taking security over assets and revenue streams.
  • Acting for a major global bank as lead arranger in a billion-dollar facility to a company with global oil and gas assets taking security over local assets.
  • Acting for one of the largest cryptocurrency exchanges by daily trading volume in the world in connection with the issuance of a stable coin backed by fiat currency including regulatory interaction and fiduciary structuring.
  • Advising one of the largest technology investment companies in the world valued at over 100 billion in connection with Bahamas cross border securities issues.
  • Advising a banking conglomerate in connection with the issuance via its Bahamas holding company of over 100 million in debt securities.
  • Structuring a crypto-focused investment fund for a significant asset manager.
  • Advising one of the major operating companies of one of the largest shipping and logistics companies in the world on the Bahamas’ economic substance requirements.

Bar Admissions

  • Bar of England and Wales
  • The Bahamas Bar


LL.B (Hons) University of Buckingham, UK
Bar Vocational Course, Manchester University, UK
Areas of Practice

Banking & Finance | Corporate, Commercial & Securities | Private Clients, Trusts & Estates | Banking & Finance | Corporate, Commercial & Securities | Private Clients, Trusts & Estates

Professional Career

Significant Accomplishments

Recognized by IFLR 1000 – Guide to the World’s Leading Financial Law Firms –  as a 2020 “Notable Practitioner”.

Citywealth IFC Power Women Top 200, 2016, for outstanding contributions to the financial services industry.

Professional Associations

The Bahamas Bar Association

The Honourable Society of Gray’s Inn


Legal Requirements Under The Bahamas' Digital Assets and Registered Exchange (DARE) Bill, 2019
Graham Thompson, June 2019

General The Securities Commission of The Bahamas (“SCB’), the independent regulatory body responsible for digital assets and investor protection, has issued the draft Digital Assets and Registered Exchange Bill (“DARE Bill”) for industry consultation. The DARE Bill prescribes the legal requirements for issuance and sale of digital tokens, and the regulation of issuers and those conducting digital asset business in or from The Bahamas...

Bahamas Regulatory Initiatives Driven by Compliance and Innovation
Graham Thompson, September 2018

It is fair to say that we are in an era of unprecedented multilateralism and convergence in tax matters. The Bahamas has already committed to the implementation of the Common Reporting Standard, having already signed onto the Multilateral Competent Authority Agreement and published its list of exchange partners with automatic exchanges that commence in September 2018...

The Bahamas' Place in a Cryptographic World: A Whitepaper
Graham Thompson, June 2018

Should The Bahamas be at the forefront of cryptocurrency regulatory policy by implementing smart, flexible regulation that encourages the legitimate operators in the sub-sector to bloom or should we leave well enough alone?The Bahamas’ position in the landscape of the cryptocurrencies is a familiar one to many in the traditional financial services economy - they’ll know this story all too well with the growth, development, and decline of private banking: a new and exciting innovation

Additional Articles

Legal Requirements Under The Bahamas’ Digital Assets and Registered Exchanges Bill, 2019 [May 2019], GT News & Insights, Vol 1 Issue 3

Investment Funds Global Practice Guide. “Law and Practice” in The Bahamas [April 2019]

Legal Update: New Bahamas Legislation to Satisfy EU Economic Substance Requirements [February 2019], GT News & Insights, Vol 1 Issue 2

Bahamas Regulatory Initiatives Driven by Compliance and Innovation [October 2018]

The Bahamas’ Place in a Cryptographic World. A Whitepaper. Released at the International Business and Finance Summit (IBFS), Nassau, The Bahamas, March 2018.

WSG's members are independent firms and are not affiliated in the joint practice of professional services. Each member exercises its own individual judgments on all client matters.

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