FCA Assertive Supervision

Calum is Global Co-Head of Litigation and Investigations. He specialises in contentious regulatory work and has very extensive experience of acting for financial institutions in high profile, complex regulatory investigations, both domestically and cross-border. He also has experience of acting for institutions in Serious Fraud Office investigations.

Calum has advised major financial institutions across a very broad range of regulatory issues, including market abuse and insider dealing, AML and anti-bribery and corruption, mis-selling, fraud, cyber security breaches, operational resilience, non-financial misconduct and other cultural issues, regulatory reporting and a broad range of other types of systems and controls failings. He also represents senior individuals in regulatory investigations.
Calum has advised extensively on the UK Senior Managers and Certification regime and on related FCA and PRA Code of Conduct and fitness and propriety issues.

Legal directories recognise Calum as a leading individual for contentious regulatory matters. Chambers UK 2024 states that "Calum is the best regulatory lawyer I have dealt with in the City; his advice is clear and succinct and his judgement is spot on. He is a trusted adviser." He has "a lot of experience and industry knowledge, and is able to smoothly run complex and large investigations".

Sarah specialises in advising clients on regulatory and internal investigations involving the most high-profile and sensitive issues, which typically attract the highest levels of scrutiny from regulators.

She has significant experience of advising on and conducting UK and cross-border investigations involving a broad range of issues, including market abuse, insider trading, financial crime (civil and criminal), cyber and data security breaches, individual accountability, operational resilience, fund liquidity issues, misselling, environmental disclosures and ‘greenwashing’, systems and controls failures, whistleblowing, cultural issues and non-financial misconduct (including, in particular, allegations of bullying, harassment, discrimination and sexual misconduct).

Sarah has a notable focus on representing clients that are involved in regulatory investigations, including in particular investigations conducted by the UK Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA), where she previously completed a secondment in its Enforcement Division. Sarah has also represented a number of clients in investigations concerning compliance with UK Listing and Takeover Code requirements.

Alongside her investigations practice, Sarah has advised over 200 clients in relation to the UK Senior Managers and Certification Regime (SMCR). Her advice spans issues relating to both the implementation and post-implementation operation of the SMCR, in addition to assisting candidates with preparations for their Senior Manager authorisations interviews with the FCA and the PRA. Sarah is specifically sought out by clients to advise them on investigations with significant individual accountability considerations, including assessments of fitness and propriety, potential breaches of the FCA and PRA Codes of Conduct and potential adjustments to individuals’ deferred remuneration, due to her expertise in these areas.

Sarah has been selected by Global Investigations Review (GIR) as one of the top 100 women in investigations, and she has also been recognised by LegalWeek/Law.com as one of the UK’s “Rising Star” female lawyers in recognition of her leading financial services contentious regulatory expertise and experience.

Marc is a highly experienced ex-regulator with over 20 years of experience at the Financial Conduct Authority (FCA) and Financial Services Authority (FSA), including 15 years at a senior leadership level.

His roles there included Head of the UK Listing Authority, Director of Market Oversight and Director of Wholesale Supervision. He sat on a number of key governance/decision-making committees including in relation to FCA Watch-list inclusion/removal, markets supervisory and policy issues, and Enforcement referrals and decision-making.

Specialising in regulatory strategy and response, Marc’s regulatory experience enables him to give clients unparalleled insights into how best to manage their most important and challenging regulatory issues.

Since joining A&O Shearman, Marc has advised clients across the broad spectrum of financial services firms, including banking, insurance, market infrastructure, wholesale broking and asset and wealth management. He specialises in advising clients, including at the Board and C-suite level, on the best strategic response to the full range of regulatory interactions, including firm visits, potential Voluntary Requirements (VREQs), Skilled Persons appointments, attestations and Watch-list inclusion.

Marc also has an extensive UK Senior Managers and Certification Regime (SMCR) and governance practice, providing SMCR training to senior management, preparation for Senior Manager’s regulatory application interviews (including Chair, CEO, CFO, COO and Branch Managers of the largest financial institutions), and advice on complex SMCR challenges. He has also undertaken fundamental reviews of firms’ implementation of the SMCR and their broader governance and oversight arrangements, providing practical recommendations in line with regulatory expectations.

Marc is approved to act as a Skilled Person for Lots B (Governance, Accountability, Strategy and Culture) and C (Controls and Risk Management Frameworks) of the FCA and PRA Skilled Persons Panel, and has also supported and advised numerous clients through the skilled person lifecycle to mitigate associated supervision and enforcement risk.

Bob is Global Co-Head of Financial Services Regulatory. He advises banks, asset managers, market infrastructure providers and other financial institutions on a wide range of national and international regulations.

He has led our substantial work on the European financial services reform agenda, including advising on revisions to capital requirements, the introduction of recovery and resolution plans and retail ring-fencing for banks and on changes to derivatives markets. Bob is the author of two chapters in the Oxford University Press publication on Financial Markets and Exchanges Law, covering UK recognised investment exchanges and clearing houses and alternative trading systems respectively. Bob gave evidence to the UK Parliamentary Commission on Banking Standards in relation to proposals for the ring-fencing of retail banking activities in the UK. He sits on the IIF Special Committee on Effective Regulation.

Bob is recognised as a leading individual for regulatory advice by Legal 500, Chambers & Partners and IFLR 1000 and is regularly quoted in the press on regulatory matters.

Olivia is an ex-regulator with significant experience of working on high profile and challenging financial services regulatory matters.

She joined A&O Shearman from the Financial Conduct Authority where she held roles across the supervision, policy and strategy divisions, and completed a year-long secondment to JP Morgan in the Office of Regulatory Affairs.

Specialising in regulatory strategy and response, Olivia uses her regulatory expertise to ensure clients proactively identify and mitigate regulatory risk and achieve the best business outcomes. She often works closely with multiple client business areas to ensure a coordinated, coherent and strategic response to regulatory issues and priorities.

Since joining A&O Shearman, Olivia has worked extensively with financial services clients to help them manage their most challenging and pressing regulatory concerns. This includes advising clients on a range of supervisory interactions and regulatory tools, such as thematic reviews and Skilled Persons appointments, and providing comprehensive strategic support to a number of high priority internal projects and regulatory change programmes. She has undertaken a number of large-scale reviews of client legal entity and group governance structures, designing rationalised and effective arrangements, and conforming them to regulatory expectations.

Olivia also has extensive experience advising clients on the UK Senior Managers and Certificate Regime (SMCR). This includes carrying out fundamental reviews of firms’ application of the SMCR, providing SMCR training to senior management, preparing candidates for Senior Manager regulatory application interviews, and advising on SMCR issues including reasonable steps.

Olivia has additionally supported a number of bank and non-bank clients on regulatory authorisations matters, including supporting licensing or variation of permissions applications and the implementation of governance, risk and compliance arrangements.