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Portrait ofSarah Brooks

Sarah Brook

Partner

Contact
CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
United Kingdom
Languages English

Sarah carries out both regulatory contentious and advisory work for a range of clients within the financial services sector, with a focus on firms that operate in the insurance market.  She assists with a range of regulatory and commercial issues affecting insurance market participants including regulatory perimeter queries; governance and conduct of business requirements; regulatory aspects of corporate deals; distribution models; product development, and authorisation applications.  In recent years Sarah has been particularly focussed on Brexit related issues and has drawn on the close relationships she has developed with counsel across the EEA to support both domestic and EEA insurers and brokers to navigate the post-Brexit world. 

From a contentious perspective Sarah has a broad range of experience in assisting clients in their relations with the Regulators, with a view to mitigating regulatory intervention.  This includes advising on supervisory reviews, regulatory enforcement actions, regulatory notifications, internal investigations, complaints brought before the Financial Ombudsman Service, and remediation exercises.  In addition, Sarah has experience of assisting on a Competition and Markets Authority market investigation following an FCA referral.
 

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Relevant experience

  • Numerous (re)insurer and broker clients on Brexit related matters, including contingency planning and the development and implementation of structures designed to ensure the smooth continuation of business activities.
  • A large investment consultancy and fiduciary management firm with its response to the FCA's proposal to refer to the sector to the CMA for a full market investigation.  Following the referral, the first of its kind, Sarah worked closely with the client throughout the market investigation and was heavily involved in drafting responses to working papers, provisional findings and the CMA's draft Order.
  • A global insurer to implement its post-Brexit reorganisation, including advising on two PRA authorisation applications and a related Part VII insurance business transfer.
  • Strategic guidance on regulatory notifications and the governance of an internal investigation to an insurance broker that had detected potential internal fraudulent activities. Conducting a detailed investigation into the potential frauds and likely root causes.  
  • A healthcare provider on the development of an innovative form of healthcare provision, including liaising with the FCA on perimeter issues, drafting the product terms and conditions and assisting with the development of marketing and training materials.
  • An individual on a highly complex FCA enforcement action, including providing strategic advice on connected matters involving a foreign regulator and a number of UK government agencies.
  • A multi-national consultancy and investment manager on the contractual architecture underpinning a multi-national pension solution offering, including drafting and negotiation.
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Education

2009 – LPC, BPP Law School, London

2008 – LL.M., University of Leicester, Leicester

2007 – LL.B., Durham University, Durham
 

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Feed

Future of Finance: regulatory briefings series 2024
London: 14 May 2024, 08.30 - 10.00am Edinburgh: 23 May 2024,  08.30 - 10.00am
04/04/2024
Lexology Masterclass: The future of AI in financial services, where innovation...
On 29 February, our CMS Financial Services Regulatory team and Nextwave hosted a Lexology Masterclass on the future of AI in financial services. In this webinar, we offered practical insights into how...
08/02/2024
Future of Finance: regulatory briefings series 2024
Join us as we launch our in-person breakfast seminar series across London and Edinburgh. In these seminars, our Financial Services team will be discussing the latest regulatory developments affecting...
06/02/2024
The impact of the Berne Financial Services Agreement
We're delighted to announce a series of informative webinars focusing on the Berne Financial Services Agreement between Switzerland and the UK, a landmark development announced on 21 December 2023. This...
08/01/2024
Switzerland and the UK sign agreement on mutual recognition in financial...
On 21 December 2023, the Swiss Federal Council and HM Treasury in the UK announced the signing of an agreement on mutual recognition in specific areas of financial services between Switzerland and the UK referred to as the Berne Financial Services Agreement (the Agreement). The conclusion of this ground-breaking Agreement is the culmination of more than two years of negotiations following the signing of a Joint Statement on 30 June 2020 aiming at enhancing cooperation in financial services between Switzerland and the UK. 
10/07/2023
Professional Indemnity Insurance Seminar 2023
The annual Professional Indemnity Seminar for insurance professionals took place on Wednesday, 7 June 2023. The event provided an update on legal issues of interest to all PI classes, as well as relevant content for specific sectors.
07/06/2023
Professional Indemnity Insurance Seminar
The annual Professional Indemnity Seminar for insurance professionals is taking place on Wednesday, 7 June 2023. As usual, the event will provide an update on legal issues of interest to all PI classes...
19/05/2023
Insurance law and regulation in United Kingdom
1. Introduction Insurers are dual regulated firms in the UK. They are authorised and regulated from a standards and policies perspective by the Prudential Regulation Authority (“PRA”) and are regulated...
29/03/2023
ESG & Insurance: Regulatory requirements and supervisory expectations
The CMS financial services regulatory team is running a series of “Bitesize briefings” for 2023, covering a range of challenging issues currently facing the sector. Our bitesize 20 minute breakfast...
24/02/2021
The FCA Test Case: Video Series
The Supreme Court delivered its keenly-an­ti­cip­ated judgment in the FCA’s Test Case on non-damage business interruption (BI) cover for losses arising from the COVID-19 pandemic on 15 January 2021. The...
19/01/2021
Business Interruption Insurance and Covid-19: FCA’s expectations following...
On 17th June 2020, the FCA published finalised guidance setting out the regulator’s expectations in respect of their regulatory obligations (under FCA Principles, ICOBS and DISP) for Insurers and insurance...
18/01/2021
Business Interruption Insurance and Covid-19: FCA’s expectations following...
The Supreme Court delivered its keenly-an­ti­cip­ated judgment in the FCA’s Test Case on non-damage business interruption (BI) cover for losses arising from the COVID-19 pandemic on 15 January 2021. The...