Expertise

Sarah has nearly two decades of experience acting for banks, asset managers and other financial services firms and senior managers 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.  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, 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 tech-enabled customer redress service, and has conducted a wide range of customer redress exercises .

Sarah's experience includes:

Work relating to market conduct and public companies

  • a director in a market abuse (misleading statements) enforcement investigation by the FCA
  • conducting independent whistleblowing investigations for a FTSE 100 global company in respect of ethical and non-financial misconduct issues
  • an individual in relation to an FCA enforcement investigation into the public statements of a listed global energy company
  • an AIM listed company into FCA enquiries arising out of an accounting fraud
  • a global plc into whistleblowing allegations relating to sexual misconduct

Financial Services

  • several PRA regulated financial institutions and listed corporates on whistleblowing investigations relating to regulatory breaches and non-financial misconduct
  • 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
  • several banks in customer redress exercises for banks. 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 bank on an FCA investigation into the sale and distribution of institutional loan notes
  • A payment firm in respect of an enforcement investigation by the Payment Systems Regulator
  • 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 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.

Education
  • Nottingham Law School (2002)
  • University of Cambridge (2001)
Publications
  • Thomson Reuters Financial Services Compliance Handbook, Internal Investigations Chapter 2020 edition
  • Securities Litigation Review, 5th Edition 2019, pub. TheLawReviews - Chapter on England and Wales (with Harry Edwards)
  • Getting the Deal Through – Financial Services Litigation (UK regulatory chapter) 2017 edition
  • Thomson Reuters Financial Services Compliance Handbook, Enforcement Chapter (with Jenny Stainsby) 2014 edition
  • CASS compliance: legal issues, unfair contract terms, and risks for senior managers. Butterworths Journal of International Banking and Financial Law July 2015 (with Hywel Jenkins)
  • "Is it time for firms to reconsider their approach to settling enforcement action?" (with Harry Edwards) Law and Financial Markets Review, November 2013
  • Attestations: what they are and what you need to know, Financial News 21 November 2013
  • "Trial by Media as a Regulatory Tool", British American Business Industry Insight, vol 1 2013
  • "Words' Worth: UK authorities are matching words with action in latest bribery enforcements", New Law Journal, October 2009 (with Alex Rene).
Languages
  • French
Testimonials

Sarah Thomas is responsive and strategic and goes the extra mile for her clients…she is easy to work with, quick off the mark, understands the issues and brings a reassuring presence.

’‘Highly competent; easy to collaborate with; always prepared; very engaging and attentive; a pleasure to work with.’

Legal 500, 2024, Financial Services: contentious regulatory