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, primarily by the FCA and PRA but also the Financial Reporting Council, US Department of Justice, and on independent public reviews and internal 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; and CASS. She is also an expert on the Senior Managers and Certification Regime, having advised numerous banks, insurers and other firms on implementation and ongoing compliance. Sarah leads our past business review and remediation service, AG Remediate.
Sarah's experience includes acting for:
- a range of PRA regulated firms on conducting whistleblowing investigations, including in relation to non-financial misconduct
- an insurance broker on settling an FCA investigation into retail insurance product mis-selling
- 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 institutional bank on an FCA investigation into the sale and distribution of institutional loan notes
- a wealth management bank on an FCA investigation into suitability of investment advice
- 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 PRA regulated firm in respect of an FCA investigation into breaches of the inducements rules
- Sarah also speaks frequently at industry conferences on a range of topics including whistleblowing, SMCR, FCA enforcement trends, and the CASS rules.
- 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).