""

Financial Regulation Compliance & Investigations

Financial Regulation Compliance & Investigations

Financial Regulation Compliance & Investigations

Download PDFDownload PDF
Print
Share

Overview

We work with the full spectrum of financial institutions to support them and provide pragmatic and commercially astute guidance to ensure they meet their vast global and local financial regulatory requirements. We help our clients ensure they are prepared for changes in regulations, that they are operating within the relevant legal framework, and that their staff are trained in and confident with their local regulatory requirements and expectations. If they become subject to an investigation by a regulator or government agency, or need to conduct an internal investigation, we advise on the investigation and dealings with external agencies. 

Across our global network of offices we work with a wide range of financial institutions in the retail and wholesale sectors, including banks, asset managers, broker-dealers, commodity traders, corporate financiers, custodians, insurance/reinsurance firms and intermediaries, life and general insurers and payment services and currency exchange platforms 

We immerse ourselves in the financial services industry, ensuring we fully understand the world our clients operate in. We combine this with an in-depth knowledge of the relevant regulators and how their authorisation, supervision and enforcement divisions operate in practice, together with technical excellence in the relevant law and regulations. A number of our team have gained direct experience from working at the regulators (including the FCA, PRA, SFO, CMA, OCC, SEC, CFTC, FINRA, CFPB and NY DFS) as well as a wide range of global financial institutions and investment exchanges. 

As well as representing financial institutions, we also advise members of senior management on their personal regulatory responsibilities, and listed companies on their regulatory requirements 

We recognize that, as much as the regulators expect a culture of compliance to pervade, in the current regulatory climate regulatory compliance advice cannot exist in a bubble. Our approach to providing regulatory compliance counsel recognizes that any compliance solution or enforcement resolution must be considered in the context of its practical impacts on our clients business. We work with our clients to develop practical, workable solutions that allow their businesses to move forward and to thrive. And when issues are identified, we conduct efficient, legally privileged investigations to obtain the factual basis to provide the best legal advice to the institution.

Experience with over 10 global regulators & agencies

  • the UK Financial Conduct Authority (FCA)
  • the UK Prudential Regulation Authority (PRA)
  • the UK Serious Fraud Office (SFO)
  • European Commission (EC)
  • the UK National Crime Agency (NCA)
  • US Department of Justice (DoJ)
  • Securities & Exchange Commission (SEC)
  • New York Department of Financial Services (DFS)
  • Commodity Futures Trading Commission (CFTC)
  • US Federal Bureau of Investigations (FBI)

Experience with over 10 global regulators & agencies

  • the UK Financial Conduct Authority (FCA)
  • the UK Prudential Regulation Authority (PRA)
  • the UK Serious Fraud Office (SFO)
  • European Commission (EC)
  • the UK National Crime Agency (NCA)
  • US Department of Justice (DoJ)
  • Securities & Exchange Commission (SEC)
  • New York Department of Financial Services (DFS)
  • Commodity Futures Trading Commission (CFTC)
  • US Federal Bureau of Investigations (FBI)
Emerging Themes in Financial Regulation & Disputes

We anticipate a pivotal year for investigations and enforcement

Our 2026 forecastIcon: arrow

Christine Cesare
Christine Cesare
+1 212 541 1228
Polly James
Polly James
+44 (0) 20 3400 3158

Kenneth M. Achenbach

Kenneth M. Achenbach
+1 404 572 6808
Christine Cesare
Christine Cesare
+1 212 541 1228
Polly James
Polly James
+44 (0) 20 3400 3158

Kenneth M. Achenbach

Kenneth M. Achenbach
+1 404 572 6808

Meet The Team

Christine Cesare
Christine Cesare
+1 212 541 1228
Polly James
Polly James
+44 (0) 20 3400 3158

Kenneth M. Achenbach

Kenneth M. Achenbach
+1 404 572 6808

Experience

  • We advised a major US investment bank on the global FX investigation. This has involved parallel investigations by regulators in the US, UK, EU, Hong Kong SAR, Singapore, Korea and Brazil.  We have advised on strategy and substance in the UK, EU and Hong Kong SAR, and have managed outside counsel in all other jurisdictions. No action was taken against our client. 
  • We are advising a leading intermediary in an FCA investigation into the implementation of the Market Abuse Regulation and systems for automated surveillance of trading. 
  • We advised a major UK listed company on an FCA investigation into alleged failure to obtain prior shareholder approval in relation to a significant acquisition. No action was taken against our client. 
  • We are regularly instructed by leading financial institutions to act as independent legal advisers (“ILAs”) for their senior management and other employees on threatened enforcement action by the FCA, PRA and overseas regulators and agencies. Our substantial experience includes acting for individuals who are asked to attend regulatory interviews as witnesses, as well as individuals who are themselves the subject of a formal investigation. 
  • We advised a leading global insurer on an FCA (and subsequent European Commission) investigation into suspected information sharing and other anti-competitive conduct in relation to the aviation insurance market. No action was taken against our client. 
  • We advised a range of financial institutions, including non-EEA banks, in relation to their implementation of MiFID II, the largest and most onerous regulatory reform package to affect the European financial services sector in recent years

Related Insights

Insights
Jan 27, 2026

U.S. Securities Enforcement: Our predictions for 2026

Consistent with patterns from past administrations, we expect U.S. securities enforcement to accelerate modestly in 2026. The SEC and FINRA will likely focus increasingly on cases about foreign actors, artificial intelligence (AI), and other emerging technologies, alongside traditional areas of enforcement with an emphasis on addressing investor harm. 
Insights
Jan 26, 2026

From incentives to implications - navigating Early Account Schemes in a multi-regulator world

The UK regulatory landscape is evolving towards more subject-led enforcement models designed to accelerate investigations and deliver swifter outcomes. Early Account Schemes (EAS), implemented by the Prudential Regulation Authority (PRA) and now contemplated by the Office for Financial Sanctions Implementation (OFSI), allow firms to self-investigate and report misconduct in exchange for the opportunity of enhanced settlement discounts, quicker resolution, and greater visibility and control over the process. While an EAS scheme offers clear benefits, it also raises complex legal and strategic considerations – particularly for financial sector firms facing overlapping regulatory regimes, where a single issue may trigger scrutiny from multiple regulators. Navigating overlapping regulatory regimes requires careful consideration and planning. Choosing to cooperate through an EAS scheme may present additional challenges and risks, particularly where an alleged sanctions breach could expose the firm to potential criminal liability.
Insights
Jan 26, 2026

UK Financial Ombudsman Service Reforms: Key Changes and Impacts

In July 2025, HM Treasury (“HMT”) published a consultation paper (the “HMT Consultation Paper”) outlining significant reforms to the Financial Ombudsman Service (“FOS”). At the same time, the Financial Conduct Authority (“FCA”) and FOS published a consultation paper (the “FCA/FOS Consultation Paper”) designed to be read alongside HMT’s proposals whilst setting out their own proposals for reform. BCLP responded to both consultations last year, and further developments are now expected in 2026, with the FCA confirming plans to issue a Policy Statement in the first half of the year.   From its origins as an informal financial services dispute resolution mechanism, the FOS has evolved into an entity that many now view as problematic. The Chancellor, in her 2025 Mansion House speech, described its reform as the biggest of all of the proposed reforms launched. According to HMT, industry stakeholders believe the current FOS has been “impacting investment in UK financial services and inhibiting innovation by firms”. Getting this reform right is therefore crucial to the Government’s growth agenda.   In this article, we consider some of the key aspects of the proposed changes and highlight some significant issues that must be considered before the proposals are implemented. 

Related Insights

Insights
Jan 27, 2026
Rebalancing risk to unlock growth: How financial services regulation will shape the economy in 2026
Insights
Jan 27, 2026
U.S. Securities Enforcement: Our predictions for 2026
Consistent with patterns from past administrations, we expect U.S. securities enforcement to accelerate modestly in 2026. The SEC and FINRA will likely focus increasingly on cases about foreign actors, artificial intelligence (AI), and other emerging technologies, alongside traditional areas of enforcement with an emphasis on addressing investor harm. 
Insights
Jan 26, 2026
CP25/42: The FCA’s prudential reset for crypto firms
Insights
Jan 26, 2026
CRD VI: Preparing for Changes in Cross-Border Lending in 2026
Insights
Jan 26, 2026
FCA CP25/40 explained: What the UK’s new crypto regulations mean in practice
Insights
Jan 26, 2026
FCA CP25/41: Admissions, disclosures and market abuse in crypto
Insights
Jan 26, 2026
From incentives to implications - navigating Early Account Schemes in a multi-regulator world
The UK regulatory landscape is evolving towards more subject-led enforcement models designed to accelerate investigations and deliver swifter outcomes. Early Account Schemes (EAS), implemented by the Prudential Regulation Authority (PRA) and now contemplated by the Office for Financial Sanctions Implementation (OFSI), allow firms to self-investigate and report misconduct in exchange for the opportunity of enhanced settlement discounts, quicker resolution, and greater visibility and control over the process. While an EAS scheme offers clear benefits, it also raises complex legal and strategic considerations – particularly for financial sector firms facing overlapping regulatory regimes, where a single issue may trigger scrutiny from multiple regulators. Navigating overlapping regulatory regimes requires careful consideration and planning. Choosing to cooperate through an EAS scheme may present additional challenges and risks, particularly where an alleged sanctions breach could expose the firm to potential criminal liability.
Insights
Jan 26, 2026
Non-financial misconduct regulation – regulatory overreach, or progressive risk management strategy?
Insights
Jan 26, 2026
UK Financial Ombudsman Service Reforms: Key Changes and Impacts
In July 2025, HM Treasury (“HMT”) published a consultation paper (the “HMT Consultation Paper”) outlining significant reforms to the Financial Ombudsman Service (“FOS”). At the same time, the Financial Conduct Authority (“FCA”) and FOS published a consultation paper (the “FCA/FOS Consultation Paper”) designed to be read alongside HMT’s proposals whilst setting out their own proposals for reform. BCLP responded to both consultations last year, and further developments are now expected in 2026, with the FCA confirming plans to issue a Policy Statement in the first half of the year.   From its origins as an informal financial services dispute resolution mechanism, the FOS has evolved into an entity that many now view as problematic. The Chancellor, in her 2025 Mansion House speech, described its reform as the biggest of all of the proposed reforms launched. According to HMT, industry stakeholders believe the current FOS has been “impacting investment in UK financial services and inhibiting innovation by firms”. Getting this reform right is therefore crucial to the Government’s growth agenda.   In this article, we consider some of the key aspects of the proposed changes and highlight some significant issues that must be considered before the proposals are implemented.