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Elisabeth Bremner


CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English

Elisabeth is a Partner in the Financial Services Regulatory team at CMS. She has more than 25 years’ experience representing financial institutions in cases involving both UK and overseas regulators, dealing with contentious supervisory interventions through to regulatory investigations and enforcement action. She is also frequently appointed as a trusted advisor to members of senior management when facing their own individual investigations.

She has significant experience in cases concerning insider dealing, market abuse, trader mis-marking and financial crime risks in the wholesale sector. Within the retail industry she has expertise in representing clients on cases relating to mis-selling, consumer redress programmes and complaints mishandling. Increasingly she advises on whistleblower investigations and provides support on implementing connected policies and frameworks. She has also advised and acted on high profile conduct issues in the SME corporate banking sector.

Elisabeth has previously spent time at a major bank where she managed the global retail internal investigations team. She has been appointed as a Skilled Person by both the PRA and FCA on various engagements. She also sits on The Investing and Savings Alliance (TISA) Consumer Engagement Policy Committee, helping the investment industry respond to regulatory change.

Elisabeth has been independently nominated an Acritas Star by in-house counsel in a global client survey. She is individually ranked in Chambers UK.

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“She has a lot of experience in the area and a calm demeanour. She’s good at steering people through the process and looks out for their interests.”

Chambers & Partners 2023

“She has a really bright and insightful way about her and how she looks at cases and deals with clients. She handles matters from a more creative angle.”

Chambers & Partners 2022

“She's a truly outstanding lawyer: deeply knowledgeable, thoughtful, tenacious, collaborative and immensely hard-working.”

Chambers & Partners 2021

"She is a pleasure to work with according to clients who highlight her ability to understand the big picture and all stakeholders’ perspectives, with tremendous grasp of the details and impressive knowledge."

Chambers & Partners 2020

“She provides outstanding service, her attention to detail is remarkable and she is tenacious in pursuit of fair outcomes for her clients.”

Chambers & Partners 2019

“Elisabeth Bremner is a ‘superstar’ in the regulatory matters we consult on with her”.

IFLR 1000 Review 2016 – Financial and Corporate


  • A Practitioner’s Guide to Individual Conduct and Accountability in Financial Services Firms Thomson Reuters 2016
  • The Practitioner’s Guide to Global Investigations GIR 2017 and 2018
  • Former editor of Butterworths Financial Regulation Service (DEPP)
  • Compliance Complete, The Insurers Compliance Handbook – Enforcement, Thomson Reuters online current
  • Compliance Complete, The Compliance Handbook – Internal Investigations, Thomson Reuters online
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1996 - Admitted as a Solicitor

1994 - Legal Practice Course: Commendation - College of Law Chester, Chester

1993 - BA (Hons) (Law) 2:1 - Durham University, Durham

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FCA publishes Consumer Duty outcomes review – what do I need to know?
The FCA has published the results of its multi-firm review into Consumer Duty outcomes monitoring. Although the review concentrated on 20 of the larger insurance firms, the FCA’s observations are relevant...
FCA publishes Consumer Duty outcomes review – what do I need to know?
The FCA has published the results of its multi-firm review into Consumer Duty outcomes monitoring. Although the review concentrated on 20 of the larger insurance firms, the FCA’s observations are relevant...
Consumer Duty Toolkit – Annual Board reports
The FCA has made clear that the Consumer Duty should be a top priority for Boards. Boards must review and approve an annual assessment of whether the firm is delivering good outcomes for their customers by 31 July 2024. Firms should be able to demonstrate how their business model, the actions they have taken, and their culture embed the objectives of the Consumer Duty.  The annual assessment should include:   Before signing off the assessment, the Board should agree the action required to address poor outcomes, any identified risks and agree on any necessary changes to the firm’s business strategy. The assessment will be part of the evidence the FCA uses to assess a firm’s compliance with the Consumer Duty. The FCA may ask to see the annual assessment and Board attestation, including the supporting data and related Board minutes. These materials should be sufficiently robust and evidence a developmental mindset – showing how the firm is focussed on customer outcomes, gaps they have identified and necessary actions to improve products and services. There is no set format to the assessment. Different treatments will be required depending on the complexity of the business, its products and services, its customers and role in the distribution chain. Each firm will be best placed to determine how to present information. Firms will need to consider:Before the Board approves the assessment, it should:For more information and guidance on preparing the annual assessment, click the link below.
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...
The future of the FCA’s Consumer Duty: Hopes and Expectations
Join us for an in-person panel discussion on the future of the Consumer Duty on 18 October starting at 4.30pm at our offices. The event will be chaired by Elisabeth Bremner, partner in our Financial Services...
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.
Consumer Duty
In this section: The wait is over: Consumer Duty comes into force FCA Consumer Duty – Implementation toolkit Consumer Duty Toolkit - Annual Board reports CMS Financial Services Regulation Bitesize Briefings – The new Consumer Duty
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...
Current Issues in Contentious Financial Regulation - Part 3
Apologies, but the wrong registration link was used in the previous invite. If you would like to register for this event, please use the correct link below. Sometimes things don’t go to plan and when...
Current Issues in Contentious Financial Regulation - Part 1
Apologies, but the wrong registration link was used in the previous invite. If you would like to register for this event, please use the correct link below. Sometimes things don’t go to plan and when...
Webinar: Current Issues in Contentious Financial Regulation - the FCA’s...
Speakers Simon Morris Partner CMS Simon has been a partner in the firm’s Financial Markets team since 1988, having joined the firm in 1980 and qualified as a solicitor in 1982. He advises a wide range...
FCA Consumer Duty – Implementation Toolkit
FCA has published its final rules and guidance for a new Consumer Duty that will set higher and clearer standards of consumer protection across financial services and require firms to put their customers’ needs first. Acting to deliver good outcomes should be at the centre of firms’ strategies and business objectives. FCA wants to see increased confidence from consumers, ensuring they are equipped with the right information and the right support to make effective, timely and properly informed decisions.  The Duty includes requirements for firms to: give fair value;ensure customers don’t face unreasonable barriers when they want to switch or cancel products or complain;provide helpful and accessible customer support;take appropriate action to mitigate the risk of actual or foreseeable harm;provide timely and clear information about products and services that customers can understand so they can make good financial de­cisions;provide products and services that are right for their customers; andfocus on the real and diverse needs of their customers, including those in vulnerable circumstances, at every stage and in each interaction. Throughout, the FCA references a renewed focus on the need for firms to understand how their customers behave in practice and how they make decisions. Firms will need to be able to demonstrate that they have considered consumer behavioural biases at all stages of the product lifecycle. The rules require firms to monitor and regularly review the outcomes their customers are experiencing to ensure that their products and services deliver good outcomes and to take action where this is not the case. The consumer duty is also reflected in the SM&CR, with responsibilities on senior managers and all conduct rules staff to act to deliver good customer outcomes. The FCA is giving firms 12 months to implement the new rules for all new and existing products and services. The rules will be extended to closed book products 12 months later, to give firms more time to review what may be a large number of closed products. Firms are expected to make full use of the implementation periods – FCA has set down a timetable of key milestones, the first of which is the end of October 2022 when boards (or equivalent bodies) are expected to have scrutinised and agreed their firms’ implementation plans. How the duty applies and what it means in practice will vary by sector and by firm. Some firms will already be meeting parts of the new standards through their compliance with existing handbook provisions, and the Duty will apply proportionately depending on the nature of firms’ offerings and their customer base. But all firms will need to map their business to the new Duty and be able to evidence how they are monitoring and acting to deliver good outcomes.  The implementation timetable is likely to prove challenging and firms will need to begin assessing their business and what the Duty means for them without delay. To help you navigate this process, we have created our Consumer Duty Toolkit setting out the steps for firms to consider and how we can support you through your implementation programmes.