Sarah has more than a decade 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 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 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 its implementation.


Highlights include acting for:

  • 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 global investment bank on an FCA investigation into corporate banking AML systems and controls
  • 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
  • a European institutional bank on an FCA investigation into the sale and distribution of institutional loan notes 
  • a UK private wealth bank and several of its senior management in an FCA investigation, settlement process, and subsequent customer redress in relation to the AIG enhanced bond
  • Sir Christopher Kelly on his independent public review of the Co-operative Bank
  • a retail investment platform in an FCA investigation, settlement process and final notice in respect of its compliance with the CASS rules
  • a central bank in connection with LIBOR investigations and prosecutions 

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


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)

Year qualified
  • 2004
  • Gonville & Caius College, Cambridge University, BA in law, 2001
  • LPC, Nottingham Law School, 2002
  • French