Home / People / Sam Robinson
Portrait of Sam Robinson

Sam Robinson


CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
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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  • 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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  • 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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FCA out­lines plans for the in­tro­duc­tion of a reg­u­lat­ory gate­way for firms...
Fol­low­ing HM Treas­ury’s pro­pos­al to pro­hib­it au­thor­ised firms from ap­prov­ing fin­an­cial pro­mo­tions from un­au­thor­ised per­sons, un­less they have suc­cess­fully passed through a new “reg­u­lat­ory gate­way”...
Changes to crypto reg­u­la­tion on the ho­ri­zon
On 20 Ju­ly 2022, the Fin­an­cial Ser­vices and Mar­kets Bill (the Bill) was in­tro­duced in­to Par­lia­ment.  The Bill is the largest piece of fin­an­cial ser­vices le­gis­la­tion for over two dec­ades and cov­ers...
Di­git­al As­sets and Web3 Hub
At CMS we are truly in­ter­ested in everything crypto, block­chain and meta­verse. We en­joy co­oper­at­ing with in­dustry bod­ies and aca­dem­ics, have our voice heard in gov­ern­ment think­ing groups and tasks forces, at­tend and or­gan­ise events and reg­u­larly pub­lish leg­al brief­ings, re­search re­ports and opin­ion pieces.   This page con­tains some of our most re­cent pub­lic­a­tions. If any of the art­icles have your par­tic­u­lar in­terest, feel free to reach out to its au­thors for a deep­er con­ver­sa­tion.
New bill on the block(chain): The Eco­nom­ic Crime and Cor­por­ate Trans­par­ency...
On 22 Septem­ber 2022, the UK Gov­ern­ment in­tro­duced the Eco­nom­ic Crime and Cor­por­ate Trans­par­ency Bill. The bill, the second eco­nom­ic crime bill of this year, is the most re­cent ef­fort by the UK Gov­ern­ment...
The Law Com­mis­sion’s con­sulta­tion pa­per on di­git­al as­sets (cor­por­ate law...
In Ju­ly 2022, the Law Com­mis­sion for Eng­land and Wales launched its con­sulta­tion pro­pos­als in­vit­ing com­ments and re­cog­ni­tion for pro­tec­tion of di­git­al as­sets (such as crypto-tokens, cryptoassets and non-fun­gible...
FCA fi­nal rules chal­lenge fin­an­cial pro­mo­tions of high-risk in­vest­ments
On 1 Au­gust 2022, in a bid to tackle mis­lead­ing ad­verts that en­cour­age in­vest­ment in high-risk products, the FCA pub­lished stronger rules re­lat­ing to the fin­an­cial pro­mo­tions of high-risk in­vest­ments...
Fin­an­cial Ser­vices & Mar­kets Bill: A new be­gin­ning? UK fin­an­cial ser­vices...
On 20 Ju­ly 2022, the Fin­an­cial Ser­vices and Mar­kets Bill (the Bill) was in­tro­duced in­to Par­lia­ment. The Bill is the largest piece of fin­an­cial ser­vices le­gis­la­tion for over two dec­ades and cov­ers a wide...
Crypto and ESG - 11 things you need to know…
Cryptoassets are in the spot­light for many reas­ons. The use of crypto­cur­ren­cies as an al­tern­at­ive to fi­at cur­ren­cies is be­ing ex­plored and tested fur­ther by glob­al events. Cryptoassets and block­chain...
Amend­ments to the UK MLRs – 14 key changes to know now
HM Treas­ury launched a con­sulta­tion on 22 Ju­ly 2021 (Con­sulta­tion), which out­lined how the gov­ern­ment in­ten­ded to amend the UK’s money laun­der­ing re­gime to en­sure that the UK con­tin­ues to meet in­ter­na­tion­al...
Fin­an­cial Mar­ket In­fra­struc­tures – a new era of re­spons­ib­il­ity for in­di­vidu­als
HMT has an­nounced that it in­tends to pro­ceed with its new Seni­or Man­agers & Cer­ti­fic­a­tion Re­gime (SM&CR) for fin­an­cial mar­ket in­fra­struc­tures (FMIs).  The new re­gime will be sim­il­ar to the SM&CR for...
CMS Glob­al Fintech Up­date - May 2022
Be­low you will find the top­ics of the May 2022 news­let­ter:Fintech in Bel­gi­umFintech in Colom­bi­aFintech in Ita­ly­Fintech in Slov­e­ni­aFintech in Spain­Fintech in Switzer­land­Fintech in UAEFintech in United King­dom 
UK an­nounces mul­tiple de­vel­op­ments to make the UK a glob­al hub for cryptoassets...
On 4 April 2022, key an­nounce­ments were made re­gard­ing the de­vel­op­ment of the UK cryptoasset sec­tor with the aim of mak­ing it a glob­al hub for cryptoassets. HM Treas­ury (“HMT”) pub­lished a re­sponse...