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Samantha Paul


Samantha Paul
  1. People

Samantha Paul

Samantha Paul

Knowledge & Innovation Counsel


London

Samantha Paul
  1. People

Samantha Paul

Samantha Paul

Knowledge & Innovation Counsel


London

Samantha Paul

Knowledge & Innovation Counsel

London

T: +44 (0) 20 3400 3194

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  • Biography

Biography

Samantha is a skilled lawyer with extensive private practice and in-house experience of handling complex, multi-jurisdictional regulatory and criminal investigations, English and overseas litigation, and related advisory work.

Samantha brings this experience to her role as BCLP’s Principal Knowledge & Innovation Counsel for the Financial Services Disputes and Investigations Practice Group and the White Collar team. Her role includes providing legal knowledge, training and thought leadership, as well as promoting particular capabilities to existing and potential clients. She also assists the teams with strategy, development and innovation initiatives.

Before joining BCLP, Samantha worked for a number of years in the Financial Services Litigation team at another international law firm, where her experience included acting on a long-running multi-jurisdictional investigation in relation to LIBOR for a well-known bank.

Samantha then moved in-house, serving as Senior Counsel in the Litigation and Regulatory Enforcement team at an international investment bank.  Her in-house experience includes taking a lead role in the handling of investigations into allegations of misconduct relating to foreign exchange benchmarks, transaction monitoring in connection with sanctions, and suspicious transactions raising anti-money laundering concerns.

She has experience across the full lifecycle of regulatory and criminal investigations by multiple regulators and prosecutors, from initial discharge of investigations through to outcome and full remediation.  She also has experience handling follow-on and related employment and civil litigation in various jurisdictions. 

Emerging Themes in Financial Regulation & Disputes

We anticipate a pivotal year for investigations and enforcement

Our 2026 forecastIcon: arrow

Related Capabilities

Financial Services Corporate & Regulatory Team Financial Services Corporate & Regulatory Team

Financial Regulation Compliance & Investigations Financial Regulation Compliance & Investigations

  • Financial Services Corporate & Regulatory Team

  • Financial Regulation Compliance & Investigations

Related Insights

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Insights
Apr 21, 2026

CP26/13: The FCA sharpens the cryptoasset regulatory perimeter

As crypto moves from the margins to the mainstream of the UK financial system, regulatory uncertainty is giving way to structured supervision, authorisation and enforcement. BCLP’s Emerging Themes 2026 crypto series tracks this transition in real time — from the expansion of the regulatory perimeter, through new conduct and market integrity regimes, to the operational and governance expectations that will define participation in regulated crypto markets. This article focuses on the latest step in that progression: the FCA’s publication of its perimeter guidance in Consultation Paper CP26/13, a critical development in translating legislative intent into practical compliance obligations as the UK’s new crypto regime takes shape.
Insights
Apr 07, 2026

Cyber Resilience in Financial Services: Navigating Rising Risks and the 2026 Regulatory Shift

UK regulators have not yet fully exercised the breadth of their powers to address shortcomings in organisational cyber‑security measures—but that restraint is unlikely to continue. The policy statements published on 18 March 2026 by the FCA, PRA and Bank of England, introducing a new single regime for operational incident and third‑party reporting, signal the direction of travel. The framework—under which firms must report serious cyber and operational incidents through a unified portal and provide structured information on their critical third party (CTP) dependencies—reflects the UK regulators’ sharpened focus on digital risk, system resilience, and their recognition of the vulnerabilities inherent in  complex technological supply chains. This shift sits alongside the UK government’s broader agenda. As the Cyber Security and Resilience (Network and Information Systems) Bill (NIS Bill) progresses and HM Treasury (HMT) prepares to designate major technology providers as CTPs using its FSMA powers, firms can expect a step‑change in supervisory expectations. Cyber‑security, data protection and operational resilience disciplines must now operate as a single, evidence‑based ecosystem capable of withstanding assertive regulatory challenge. The coming year will require firms not only to demonstrate alignment on paper, but to evidence—consistently and credibly—that controls work in practice. This article is the first in our three part Emerging Themes in Financial Regulation & Disputes 2026 series. We examine the evolving regulatory and risk landscape shaping cyber and operational resilience expectations for the year ahead—and set out practical priorities for financial services firms seeking to respond proactively. Our accompanying articles will examine (i) the evolving cyber litigation risks facing financial services firms and (ii) operational resilience and the growing influence of CTP designations.
Insights
Feb 11, 2026

FCA publishes further information on its approach to the UK’s new cryptoasset regime

Insights
Feb 05, 2026

FCA Enforcement Watch and Beyond – Five Headline Trends for 2026

Insights
Jan 27, 2026

Rebalancing risk to unlock growth: How financial services regulation will shape the economy in 2026

Insights
Dec 18, 2025

AI Regulation in Financial Services: Turning Principles into Practice

As 2026 approaches, the UK financial services sector stands at a pivotal moment in its AI journey. What began as cautious pilots has matured into widespread deployment, prompting regulators to sharpen their focus on governance and risk. The FCA’s recent oral evidence to the Treasury Committee inquiry on AI in financial services — and Chief Executive Nikhil Rathi’s recent remarks at the FT Global Banking Summit — highlight the delicate balance: promoting innovation while protecting consumers and financial stability.
Insights
Dec 04, 2025

Enhancing Banks’ and Insurers’ Approaches to Managing Climate-Related Risks

On 3 December 2025, the PRA published Policy Statement 25/25 (PS25/25), finalising proposals from CP10/25 and introducing Supervisory Statement 4/25 (SS4/25). This replaces SS3/19 and sets out updated expectations on how banks and insurers should manage climate-related financial risks.
Insights
Nov 04, 2025

Clarity on the FCA’s approach to naming firms under investigation

The High Court’s recent judgment in R (CIT) v FCA [2025] EWHC 2614 (Admin) provides critical clarity on the FCA’s powers to name firms under investigation. Upholding the regulator’s decision to publicise its probe into a yet unnamed firm, referred to as “CIT”, the court reaffirmed the legitimacy of the FCA’s “exceptional circumstances” test, rejecting arguments that the regulator had misapplied its Enforcement Guide. This ruling comes amid heightened scrutiny of the FCA’s enforcement transparency, following its abandoned proposal to adopt a broader “public interest” test. The judgment not only reinforces the high threshold for naming firms but also delineates the boundaries of judicial oversight, confirming that decisions on exceptionality and desirability rest primarily with the FCA, subject to reasonableness review. For firms navigating regulatory risk, the decision signals a more assertive, but still constrained, approach to public disclosures by the FCA.
Insights
Nov 03, 2025

FCA Update on Non-Financial Misconduct and Culture in Financial Services

Related Insights

Insights
Apr 21, 2026
CP26/13: The FCA sharpens the cryptoasset regulatory perimeter
As crypto moves from the margins to the mainstream of the UK financial system, regulatory uncertainty is giving way to structured supervision, authorisation and enforcement. BCLP’s Emerging Themes 2026 crypto series tracks this transition in real time — from the expansion of the regulatory perimeter, through new conduct and market integrity regimes, to the operational and governance expectations that will define participation in regulated crypto markets. This article focuses on the latest step in that progression: the FCA’s publication of its perimeter guidance in Consultation Paper CP26/13, a critical development in translating legislative intent into practical compliance obligations as the UK’s new crypto regime takes shape.
Insights
Apr 07, 2026
Cyber Resilience in Financial Services: Navigating Rising Risks and the 2026 Regulatory Shift
UK regulators have not yet fully exercised the breadth of their powers to address shortcomings in organisational cyber‑security measures—but that restraint is unlikely to continue. The policy statements published on 18 March 2026 by the FCA, PRA and Bank of England, introducing a new single regime for operational incident and third‑party reporting, signal the direction of travel. The framework—under which firms must report serious cyber and operational incidents through a unified portal and provide structured information on their critical third party (CTP) dependencies—reflects the UK regulators’ sharpened focus on digital risk, system resilience, and their recognition of the vulnerabilities inherent in  complex technological supply chains. This shift sits alongside the UK government’s broader agenda. As the Cyber Security and Resilience (Network and Information Systems) Bill (NIS Bill) progresses and HM Treasury (HMT) prepares to designate major technology providers as CTPs using its FSMA powers, firms can expect a step‑change in supervisory expectations. Cyber‑security, data protection and operational resilience disciplines must now operate as a single, evidence‑based ecosystem capable of withstanding assertive regulatory challenge. The coming year will require firms not only to demonstrate alignment on paper, but to evidence—consistently and credibly—that controls work in practice. This article is the first in our three part Emerging Themes in Financial Regulation & Disputes 2026 series. We examine the evolving regulatory and risk landscape shaping cyber and operational resilience expectations for the year ahead—and set out practical priorities for financial services firms seeking to respond proactively. Our accompanying articles will examine (i) the evolving cyber litigation risks facing financial services firms and (ii) operational resilience and the growing influence of CTP designations.
Insights
Feb 11, 2026
FCA publishes further information on its approach to the UK’s new cryptoasset regime
Insights
Feb 05, 2026
FCA Enforcement Watch and Beyond – Five Headline Trends for 2026
Insights
Jan 27, 2026
Rebalancing risk to unlock growth: How financial services regulation will shape the economy in 2026
Insights
Dec 18, 2025
AI Regulation in Financial Services: Turning Principles into Practice
As 2026 approaches, the UK financial services sector stands at a pivotal moment in its AI journey. What began as cautious pilots has matured into widespread deployment, prompting regulators to sharpen their focus on governance and risk. The FCA’s recent oral evidence to the Treasury Committee inquiry on AI in financial services — and Chief Executive Nikhil Rathi’s recent remarks at the FT Global Banking Summit — highlight the delicate balance: promoting innovation while protecting consumers and financial stability.
Insights
Dec 04, 2025
Enhancing Banks’ and Insurers’ Approaches to Managing Climate-Related Risks
On 3 December 2025, the PRA published Policy Statement 25/25 (PS25/25), finalising proposals from CP10/25 and introducing Supervisory Statement 4/25 (SS4/25). This replaces SS3/19 and sets out updated expectations on how banks and insurers should manage climate-related financial risks.
Insights
Nov 04, 2025
Clarity on the FCA’s approach to naming firms under investigation
The High Court’s recent judgment in R (CIT) v FCA [2025] EWHC 2614 (Admin) provides critical clarity on the FCA’s powers to name firms under investigation. Upholding the regulator’s decision to publicise its probe into a yet unnamed firm, referred to as “CIT”, the court reaffirmed the legitimacy of the FCA’s “exceptional circumstances” test, rejecting arguments that the regulator had misapplied its Enforcement Guide. This ruling comes amid heightened scrutiny of the FCA’s enforcement transparency, following its abandoned proposal to adopt a broader “public interest” test. The judgment not only reinforces the high threshold for naming firms but also delineates the boundaries of judicial oversight, confirming that decisions on exceptionality and desirability rest primarily with the FCA, subject to reasonableness review. For firms navigating regulatory risk, the decision signals a more assertive, but still constrained, approach to public disclosures by the FCA.
Insights
Nov 03, 2025
FCA Update on Non-Financial Misconduct and Culture in Financial Services

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