Home / People / Sam Robinson
Portrait ofSam Robinson

Sam Robinson

Partner

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

Sam is a partner in the Financial Services Regulatory practice.

Sam advises clients include banks, asset management firms, broker dealers, payment institutions and corporate finance houses on a broad range of regulatory and compliance matters within the financial services sector. Prior to working in private practice, Sam worked for seven years at the UK financial services regulator, the Financial Services Authority (the majority of this time in the FSA’s General Counsel’s Division), and has also spent time on secondment at Santander Asset Management UK Limited.

Recent work includes advising on whether certain activities require FCA authorisation, establishing crowdfunding platforms and robo-managers, the structuring of fund vehicles (including regulated and unregulated funds), financial promotion issues, conduct of business requirements, acquisitions of FCA-authorised firms, drafting terms of business for investment firms and payment service providers as well as providing consumer credit advice.

Sam has been published in financial services publications and journals (including Bloomberg World Securities Law Reports, Bloomberg UK Financial Services Law Reports and Thomson Reuters Compliance Complete). Sam has also been a guest lecturer on the IPF Diploma in Investment Education.

Sam won an award for the Regulatory Lawyer of the Year at the Thomson Reuters Compliance Awards 2014 (http://www.complianceawards.com/2014-winners). Sam was also shortlisted for the same award in 2013.

more less

"Financial services regulatory expert Sam Robinson is 'sought out by innovators for being able to navigate mazes by thinking laterally'."

Legal 500, 2018

"Sam has "regulatory expertise, which sources praise him for contextualising in a "very commercial" manner" and "Sam's great. He's very sharp but comes across as laid back. I'm always confident he knows what he's doing since he knows the regulatory framework thorough"."

Chambers, 2018

“the ‘pragmatic’ Sam Robinson has ‘deep industry knowledge’ across a range of matters including payment regulatory issues.”

Legal 500 2015

Relevant experience

  • Establishing new businesses – Assisting with FCA authorisation applications and advising firms on the regulatory requirements relating to the launch of a new business.
  • FinTech – Advising clients in the FinTech industry relating to regulatory requirements including crowdfunding platforms, peer-to-peer lending platforms, robo-managers, e-money providers and payment services firms.
  • Crowdfunding - Extensive experience advising crowdfunding platforms and investors and advise over 30 crowdfunding platforms covering equity, debt, real estate, peer-to-peer lending and invoice financing.  
  • Regulatory change projects – Fund managers on AIFMD, investment firms on MiFID I and MiFID II, changes in FCA rules.
  • New products and services – Advising various firms including banks, investment firms and asset managers on the launch of new products and services.
  • Compliance with PRA and FCA Rules and EU financial services regulation – Advising clients on regulatory requirements including in relation to systems and controls, conduct of business, approved persons and regulatory capital.
  • Contracts – Drafting and negotiating contracts including customer terms of business, investment management agreements, custody agreements, appointed representative agreements, distribution agreements and outsourcing agreements.
more less

Memberships & Roles

  • Member of the Alternative Investment Management Association.
  • Member of the Financial Services Lawyers Association.
  • Member of the Prepaid International Forum
  • Legal advisor to the UK Crowdfunding Association.
more less

Publications

  • Sam is regularly published in financial services publications and journals on a wide range of financial services issues (including Bloomberg World Securities Law Reports, Bloomberg UK Financial Services Law Reports, Lexis Nexis, Thomson Reuters Compliance Complete and E-Finance & Payments Law & Policy). 
more less

Education

  • LLB Law
  • LLM Law (Corporate and Securities Law)
  • Securities Institute Diploma – Regulation and Compliance
  • Securities and Futures Authority – Securities Representative
  • Securities and Futures Authority – Financial Derivatives Representative
more less

Feed

28/03/2024
FCA Publishes Finalised Guidance on Financial Promotions on Social Media
The Financial Conduct Authority (“FCA”) has published its finalised guidance on financial promotions on social media (FG24/1) (the “Guidance”). This follows a consultation carried out by the FCA...
28/03/2024
FCA Publishes Finalised Guidance on Financial Promotions on Social Media
The Financial Conduct Authority (“FCA”) has published its finalised guidance on financial promotions on social media (FG24/1) (the “Guidance”). This follows a consultation carried out by the FCA...
07/03/2024
The new UK Private Intermittent Securities and Exchange System or “PISCES”...
On 6 March 2024, the UK Government published a con­sulta­tion re­lat­ing to a new type of share trading platform, referred to as a “Private Intermittent Securities and Exchange System” or “PISCES”. ...
07/03/2024
The new UK Private Intermittent Securities and Exchange System or “PISCES”...
On 6 March 2024, the UK Government published a consultation relating to a new type of share trading platform, referred to as a “Private Intermittent Securities and Exchange System” or “PISCES”. ...
07/02/2024
CMS Expert Guide to Crypto Regulation
This Expert Guide provides an overview of cryptoasset regulation (prior to the introduction of MiCA), both inside and outside the EU. We summarise the regulations applying to the main activities performed...
Comparable
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. 
03/11/2023
UK Cryptoasset Regulation: three key updates
On 30 October 2023, HM Treasury (“HMT”) published 3 key updates on its proposed approach to regulating cryptoassets under the UK’s financial services regulatory framework, namely:Response to feedback...
02/11/2023
UK Cryptoasset Regulation: Three Key Updates
On 30 October 2023, HM Treasury (“HMT”) published 3 key updates on its proposed approach to regulating cryptoassets under the UK’s financial services regulatory framework, namely:Response to feedback...
26/09/2023
FCA introduction of new regulatory gateway for firms which approve financial...
BackgroundUnder section 21 of FSMA, currently any firm that is authorised under the Financial Services and Markets Act 2000 (FSMA), may approve a financial promotion by another unauthorised person. However...
25/09/2023
FCA introduction of new regulatory gateway for firms which approve financial...
BackgroundUnder section 21 of FSMA, currently any firm that is authorised under the Financial Services and Markets Act 2000 (FSMA), may approve a financial promotion by another unauthorised person. However...
29/06/2023
The Financial Services & Markets Act 2023 has arrived!
The Financial Services and Markets Bill has received Royal Assent to become the Financial Services and Markets Act 2023. The Act makes significant reforms to the regulation of financial services in the...
29/06/2023
The Financial Services & Markets Act 2023 has arrived!
The Financial Services and Markets Bill has received Royal Assent to become the Financial Services and Markets Act 2023. The Act makes significant reforms to the regulation of financial services in the...