Polly’s track record includes:

• Representing a Lloyd’s syndicate and several individual witnesses in relation to two (unrelated) Lloyd’s of London enforcement investigations concerning allegations of non-financial misconduct;
• Representing a former senior fund manager in a dual-track FCA enforcement investigation into alleged market manipulation;
• Representing a director of a large financial services group on an internal investigation into whistleblower allegations concerning board-level culture and conduct;
• Representing a director of a wealth management group in connection with an FCA enforcement investigation into alleged breaches of Senior Manager Conduct Rules, securing a discontinuance of the investigation;
• Representing a former SMF of a cryptocurrency trading platform in an FCA enforcement investigation concerning financial crime systems and controls;
• Advising various authorised firms facing FCA interventions using its own-initiative supervisory powers (s166 Skilled Person reviews; own initiative requirements/OIREQs, own-initiative variations of permission /OIVOPs etc);
• Representing a former senior director of a large international banking group on an internal accountability review, resulting in a total exoneration of my client;
• Conducting a cross-border trading investigation for an investment bank following allegations of front-running raised by a whistleblower;
• Conducting two (unrelated) internal investigations for international banking groups following whistleblower allegations of corrupt hiring practices;
• Conducting an internal investigation for an international banking group following allegations brought by a whistleblower of inappropriate disclosure of information between clients;
• Representing an individual client in an FCA investigation into alleged insider dealing and destruction of relevant evidence;
• Representing a former director of an asset management firm on a ‘dual track’ criminal and civil FCA enforcement investigation relating to alleged financial crime control failings, securing a discontinuance of the investigation;
• Conducting an internal investigation for a UK subsidiary of an international bank following a whistle-blower’s allegation of financial crime risk management failures;
• Leading a large team of lawyers and forensic accountants conducting a complex internal investigation into allegations of financial irregularities raised by a whistleblower in the asset-management sector;
• Representing a large international insurance group on an FCA enforcement investigation into alleged mis-selling across five jurisdictions;
• Advising firms on large or reputationally significant disputes with the Financial Ombudsman Service;

Polly’s experience includes acting on matters involving:

• Breaches of client assets (CASS) rules;
• Breaches of POCA;
• Breaches of the Money Laundering Regulations;
• Bribery and extortion
• Culture and conduct (including ‘non-financial misconduct’);
• Financial crime systems and controls breaches;
• Financial reinsurance;
• FX sales practices;
• Governance;
• Inappropriate disclosure of confidential information;
• Insider dealing;
• Market manipulation and market abuse;
• Mis-selling (insurance, pensions and mortgages);
• Mortgage arrears management;
• Non-disclosure of relevant information to regulators;
• Outsourcing oversight failures;
• Pensions mis-selling;
• Protection of whistle-blowers;
• Risk management failures / systems and controls breaches; and
• Trader mis-marking.