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Portrait of Sam 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.

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"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.
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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.
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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). 
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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
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Feed

26/07/2021
New SM&CR for FMIs pro­posed by HM Treas­ury
HM Treas­ury is pro­pos­ing to in­tro­duce a Seni­or Man­agers and Cer­ti­fic­a­tion Re­gime (“SM&CR”) for fin­an­cial mar­ket in­fra­struc­tures (“FMIs”) to en­cour­age ef­fect­ive gov­ernance, in­centiv­ise good be­ha­viour...
22/06/2021
FCA’s find­ings in­to cryptoasset con­sumer re­search 2021 – what does the...
On the 17th of June 2021, the Fin­an­cial Con­duct Au­thor­ity (“FCA”) re­leased a new pub­lic­a­tion cov­er­ing in­sights gathered from re­search in­to con­sumer at­ti­tudes to­wards the own­er­ship of crypto­cur­ren­cies.[1] ...
16/06/2021
CMS se­cures place in FCA’s reg­u­lat­ory sand­box
In­ter­na­tion­al law firm CMS has been chosen by the UK Fin­an­cial Con­duct Au­thor­ity (FCA) to par­ti­cip­ate in its 2021 reg­u­lat­ory sand­box (the sand­box). The FCA re­ceived 58 ap­plic­a­tions for the sand­box, with...
12/05/2021
CMS Glob­al Fintech Up­date
The leg­al frame­work in the fintech in­dustry is chan­ging very quickly and some­times var­ies greatly from jur­is­dic­tion to jur­is­dic­tion.Our glob­al up­date, will give you an over­view of the latest changes and top­ics we have been deal­ing with in Europe, Africa and Lat­in Amer­ica re­gion. This will give you an at a glance sum­mary of a num­ber of art­icles that we have pro­duced on a loc­al basis.For a more in-depth ana­lys­is or for any ques­tions, please reach out to your usu­al CMS con­tact or lis­ted be­low Fintech ex­perts.
12/05/2021
Has the Chan­cel­lor in­tro­duced enough new de­vel­op­ments to make a dif­fer­ence...
In his key­note speech open­ing Lon­don FinTech Week, the Chan­cel­lor of the Ex­chequer, Rishi Sunak, an­nounced a series of new policy de­vel­op­ments re­lat­ing to FinTech. In par­tic­u­lar: the launch...
10/05/2021
Wide range of new ini­ti­at­ives an­nounced for UK FinTech by Chan­cel­lor (Part...
On 19 April 2021, dur­ing his open­ing key­note speech at a launch event for FinTech Week, the Chan­cel­lor of the Ex­chequer, Rishi Sunak, an­nounced new pro­pos­als for UK FinTech, as fol­lows: A new...
06/05/2021
A look of dis­ap­prov­al: the FCA’s new dis­cus­sion pa­per on fin­an­cial pro­mo­tions...
On 29 April 2021, the Fin­an­cial Con­duct Au­thor­ity (“FCA”) pub­lished a Dis­cus­sion Pa­per DP21/1 con­cern­ing the pro­posed strength­en­ing of the fin­an­cial pro­mo­tion rules for high-risk in­vest­ments and firms...
09/03/2021
UK Budget 2021: A bright fu­ture for the UK FinTech eco­sys­tem?
On the 3rd of March 2021, Chan­cel­lor Rishi Sunak an­nounced the latest UK budget. However, it came hot on the heels of the ground-break­ing Kal­ifa Re­view in­to the UK’s flour­ish­ing FinTech in­dustry. The...
02/03/2021
Fu­ture UK fintech strategy pub­lished in Kal­ifa Re­view
Fol­low­ing the 2020 Budget, the Chan­cel­lor asked Ron Kal­ifa OBE to carry out an in­de­pend­ent re­view of the UK’s fintech sec­tor to es­tab­lish pri­or­ity areas for in­dustry, policy makers, and reg­u­lat­ors...
02/02/2021
An Up­dated Ap­proach: the FCA’s new Con­sulta­tion Pa­per CP21/3 on Pay­ment...
The Fin­an­cial Con­duct Au­thor­ity (“FCA”) pub­lished Con­sulta­tion Pa­per CP21/3 (the “Con­sulta­tion Pa­per”) on 28 Janu­ary 2021 pro­pos­ing: amend­ments to the tech­nic­al stand­ards on strong cus­tom­er...
02/02/2021
The new pruden­tial re­gime for in­vest­ment firms: key points from the first...
In Decem­ber 2020, the Fin­an­cial Con­duct Au­thor­ity (FCA) pub­lished the first of three planned Con­sulta­tion Pa­pers (CP20/24) (link) on the new UK In­vest­ment Firm Pruden­tial Re­gime (“IF­PR”), which is...
20/01/2021
ESMA ob­serves ques­tion­able re­verse so­li­cit­a­tion prac­tices after Brexit
The EU-UK Trade and Co­oper­a­tion Agree­ment and the end of the Brexit trans­ition­al peri­od on 31 Decem­ber 2020 has res­ul­ted in sig­ni­fic­ant changes to EU-UK trade in fin­an­cial ser­vices. In par­tic­u­lar, UK...