You are here

Sarah Thomas

Sarah Thomas

Senior Associate

Sarah is a financial services regulatory lawyer focussing on FCA and PRA investigations.



Sarah has more than a decade of experience acting for clients in regulatory and criminal investigations, including by the PRA, FCA, SFO, DOJ and FRC. 

Sarah is a leading City expert on the FCA's Client Money and Asset (CASS) handbook, having advised banks, trading platforms and accountancy firms on enforcement actions for breaches of the CASS rules.  Her other areas of particular expertise include the Senior Managers and Certification Regime; investment product governance and suitability; and complaints handling.

Sarah also has experience advising financial institutions on investigations and remediation exercises relating to financial crime systems and controls, investment and lending product sales processes and disclosures, pension transfers advice and a referral to the Upper Tribunal in respect of a PRA decision. Sarah advised Sir Christopher Kelly on his independent review of the Co-op Bank and is currently advising a start-up challenger bank on various aspects of its regulatory compliance.

Sarah's experience includes acting for:

  • a global investment bank on an FCA investigation into anti-money laundering systems and controls
  • a European institutional bank on an FCA investigation into sale and distribution of institutional loan notes
  • a "big four" accounting firm on an investigation into CASS (client money and assets) its reports to the FCA
  • various banks and asset managers on implementation of the Senior Managers and Certification Regime
  • a global wealth management institution on regulatory issues, complaints and litigation arising from sales of tax efficient investment products





Sarah holds a BA and MA in law from Gonville & Caius College, Cambridge and the LPC from the University of Nottingham and is admitted to practise in England and Wales. Sarah has been a judicial assistant to Court of Appeal judge Sir Anthony May.

Key Sectors