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Portrait of Elisabeth Bremner

Elisabeth Bremner

Partner

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

Elisabeth Bremner is a Partner in the Financial Services Regulatory team at CMS. Her practice focuses on contentious matters dealing with all aspects of the investigation and enforcement process. She has more than 20 years’ experience representing clients, both firms and senior managers, in cases involving both UK and overseas regulators, including the FCA, PRA (also FSA and IMRO), SFO, JFSC, SEC and CFTC. She has significant experience in undertaking independent internal investigations involving insider dealing, market abuse and trader mis-marking in the investment banking and hedge fund sectors. Within the retail industry she has expertise in investigating fraud, sanctions breaches, 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 conduct issues in the SME corporate banking sector.   

She has previously spent time at a major bank where she managed the global retail internal investigations team spanning the UK, Western Europe, Africa and India. She has acted as a Skilled Person for the FCA on a significant appointment.  She sits on the TISA Consumer Engagement Policy Committee.

In 2018, Elisabeth was independently nominated an Acritas Star by in-house counsel. Acritas interviewed over 2000 senior in-house counsel around the world and asked them to nominate outstanding lawyers with whom they had worked.  Elisabeth is also ranked individually in Chambers & Partners UK.

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"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, 2021

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

Chambers, 2020

"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, 2020

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

Chambers, 2018

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

IFLR 1000 Review 2016 – Financial and Corporate

Publications

  • 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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Education

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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Feed

30/11/2022
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...
02/11/2022
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...
03/08/2022
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.
22/06/2021
Whis­tleblow­ing
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
08/06/2021
Con­sumer re­dress pro­gramme
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
08/06/2021
Con­sumer re­dress pro­gramme
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
08/06/2021
Con­sumer re­dress pro­gramme
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
08/06/2021
Con­sumer re­dress pro­gramme
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
08/06/2021
Con­sumer re­dress pro­gramme
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
25/05/2021
Man­aging in­vest­ig­a­tions: plan­ning pres­sures and pit­falls video series
With more in­tern­al re­port­ing of con­cerns with­in busi­nesses thanks to im­proved train­ing and con­trols, and with com­plex reg­u­lat­ory, crim­in­al and HR in­vest­ig­a­tions be­com­ing more com­mon­place, cor­por­ates need...
25/05/2021
Man­aging an FCA in­vest­ig­a­tion – the in­di­vidu­als' per­spect­ive
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...
27/04/2021
Re­quire­ment to ap­point a Skilled Per­son
Some­times things don’t go to plan and when that hap­pens, firms may find them­selves hav­ing dif­fi­cult con­ver­sa­tions with the FCA.Our bites­ize break­fast brief­ings are packed with prac­tic­al tips based on...