Sarah Thomas has over a decade of experience acting for banks and other financial institutions on major regulatory investigations by the PRA, FCA, FRC and United States DOJ. She has represented clients in published regulatory decisions and investigations covering areas such as investment suitability and disclosures, AML systems and controls, institutional bond distribution, LIBOR manipulation, lending, cybersecurity and conflicts of interest. She is a City expert on the FCA’s client money and asset rules, having advised clients on FCA enforcement investigations and Section 166 reviews. Most recently, she represented PwC in its successful defence of an FRC investigation into its CASS reports on Barclays Bank, which had been fined £33 million by the FCA for its CASS breaches. Sarah also specialises in the PRA and FCA’s Senior Managers and Certification Regime and has advised over a dozen clients on their implementation of the rules.