Sarah Thomas

Expertise

Sarah is ranked as a Leading Partner in Legal 500 for Financial Services (contentious), and as a band 4 partner in Chambers & Partners.  Sarah has two decades of experience acting for clearing, investment and specialist banks, building societies, listed companies, insurance brokers, asset managers and other financial services firms and directors in high profile regulatory investigations by the FCA, PRA, PSR and Financial Reporting Council as well as the US Department of Justice, and on independent public reviews and whistleblowing investigations.  She also acts for corporates in conducting internal investigations, including whistleblowing investigations. She joined Addleshaw Goddard in June 2019 from the London financial services investigations team at Herbert Smith Freehills LLP, and has spent time on secondment at a global wealth management bank.  Sarah has particular expertise advising on investigations concerning non-financial misconduct; market abuse; financial crime systems and controls; the FCA’s conduct of business rules; complaints handling; governance and culture; anti-money laundering, consumer redress and client money and assets (CASS). Sarah devised and leads AG's AI-enabled customer redress service, and has conducted a wide range of customer redress exercises.

Sarah is currently leading on motor finance redress and related governance and regulatory risk issues. Our motor finance redress webpage is here and contains all of our thought leadership

Sarah's experience includes acting for:

Financial Services

• multiple banks and lenders in relation to motor finance commission redress and related risk and litigation issues
• an investment bank in a whistleblowing investigation into allegations of SMCR breaches and operational risk and governance failings
• an insurance intermediary in regulatory engagement concerning policy design and distribution and the regulatory perimeter
• advising a bank on a solvent wind down and related engagement with the PRA.
• Preparing the CEO and Chair of a systemic infrastructure firm for approval interviews with the Bank of England
• several PRA regulated financial institutions and listed corporates on whistleblowing investigations relating to regulatory breaches and non-financial misconduct
• an investment platform in an internal investigation into breaches of the Money Laundering Regulations, POCA and the FCA's systems and controls requirements in relation to financial crime
• several banks in respect of negotiation of, and legal issues arising from, participation in government lending schemes, including BBLS
• an insurance intermediary on an FCA enforcement and settlement in relation to sales practices
• an asset manager in respect of FCA investigations into sensitive non-financial misconduct and SMCR and HR controls
• a payment firm in respect of an enforcement investigation by the Payment Systems Regulator
• several banks in customer redress exercises in respect of financial products, bereavement processes and mortgages
• a global investment bank on an FCA investigation into corporate banking AML systems and controls*
• a major UK retail bank in respect of regulatory and complaints handling issues, and a past business review, into its sales of fixed rate loans to businesses*
• a European investment bank on an FCA investigation into the sale and distribution of institutional loan notes*
• PricewaterhouseCoopers LLP and one of its partners in the successful defence of an FRC investigation into CASS reports to the FCA in respect of Barclays Bank plc*
• a global wealth management bank on regulatory issues, litigation and FOS complaints handling and related litigation arising from sales of tax efficient film partnership investments*
• Referral to the Upper Tribunal by an Insurer in relation to a PRA decision*

Sarah also speaks frequently at industry conferences on a range of topics including whistleblowing, SMCR, FCA enforcement trends, and the CASS rules.

*experience prior to joining Addleshaw Goddard

Work relating to market conduct and public companies

• a systemically significant company on an investigation by the FRC
• a director of a listed company in relation to an FCA enforcement investigation into the public statements of a listed global energy company
• a Chairman of a listed group in an investigation in respect of allegations of insider dealing
• individuals in respect of preliminary enquiries by the FCA regarding market conduct
• conducting independent whistleblowing investigations for a FTSE 100 global company in respect of ethical and non-financial misconduct issues
• an AIM listed company into FCA enquiries arising out of an accounting fraud