"We have now submitted the final grounds of appeal to the Court of Appeal. One step closer to overturning Tom's unjust conviction. We anticipate a full hearing will take place early next year," said Hayes's lawyer, Karen Todner.
Hayes was referred to the Court of Appeal in July for his conviction after a "wide-ranging and complex" investigation by the Criminal Cases Review Commission.
Trader Tom Hayes wins right to appeal UK LIBOR rigging conviction
The CCRC, the body responsible for investigating alleged miscarriages of justice in England, Wales, and Northern Ireland, said the Court of Appeal should clarify whether the right legal approach was taken in Hayes' case.
"The CCRC has concluded that there is a real possibility that the Court of Appeal will prefer the legal approach to the definition and operation of the LIBOR rules taken by the US court and overturn Mr Hayes' conviction," it said.
Hayes, a former UBS and Citigroup trader, was found guilty of multiple charges of conspiracy to defraud by rigging the LIBOR, a benchmark used to determine interest rates on mortgages and corporate loans.
He was released from low-security prison HMP Ford in January 2021, having served around half of an 11-year sentence.
Convicted LIBOR rigger Tom Hayes has US charges thrown out
The commission noted that in January 2022 a US court judgement overturned the convictions of Deutsche Bank traders Matthew Connolly and Gavin Black. As a consequence, all charges against Hayes in the US were dropped.
In the court papers filed yesterday (20 September), Hayes' lawyers argued his conviction should be overturned based on the precedent set by the Connolly and Black rulings.
They added that during the initial trial that resulted in the 2015 conviction, the judge wrongly directed the jury, noting those directions were "wrong in law" and resulted in a trial that was "wholly unfair, and convictions which are unfair".