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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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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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Memberships

  • 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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20 May 20
FCA ac­cel­er­ates di­git­al sand­box pi­lot to sup­port firms...
18 May 20
FCA ac­cel­er­ates di­git­al sand­box pi­lot to sup­port firms amidst the...
The FCA re­leased a state­ment set­ting out its pro­pos­al to ac­cel­er­ate the di­git­al sand­box pi­lot in or­der to en­hance reg­u­lat­ory sup­port for in­nov­at­ive firms amidst the Cov­id-19 pan­dem­ic. The FCA states that...
24 March 2020
Pay­ments Solu­tions
14 May 20
European Com­mis­sion post­pones the entry in­to force of CSDR set­tle­ment...
The Com­mis­sion Del­eg­ated Reg­u­la­tion on set­tle­ment dis­cip­line (the “Set­tle­ment Dis­cip­line RTS”[1]) will now come in­to force on 1 Feb­ru­ary 2021 fol­low­ing in­dustry re­quests for more time for im­ple­ment­a­tion. ...
17 February 2020
The reg­u­lat­ory FinTech sand­box - a glob­al re­view
24 Apr 20
Crypto­cur­rency = prop­erty= leg­al pro­tec­tion
The UK Jur­is­dic­tion Taskforce’s Leg­al State­ment on the Status of Cryptoassets and Smart Con­tracts is prov­ing to be in­flu­en­tial both do­mest­ic­ally and in­ter­na­tion­ally for its ana­lys­is of the leg­al status...
2 December 2019
Cent­ral Se­cur­it­ies De­pos­it­or­ies Reg­u­la­tion - 10 things...
17 Apr 20
What does the FCA’s Busi­ness Plan 2020/2021 mean for FinTechs?
This in­form­a­tion is cor­rect as of 09:00am on 17 April 2020 and will not be main­tained. On Tues­day 7 April 2020, the UK’s Fin­an­cial Con­duct Au­thor­ity (the “FCA”) re­leased its 2020/2021 busi­ness plan...
30 Mar 20
ESMA and FCA cla­ri­fy su­per­vis­ory ap­proach on SFTR back­load­ing re­quire­ments...
This in­form­a­tion is cor­rect as of 11.30am on 30 March 2020 and will not be main­tained. The European Se­cur­it­ies Mar­kets Au­thor­ity (“ESMA”) has cla­ri­fied its po­s­i­tion on the re­quire­ments for ‘back­load­ing’...
26 Mar 20
ESMA and FCA is­sue state­ments con­cern­ing reg­u­lat­ory for­bear­ance for...
Cor­rect as of 12pm on 23 March. This art­icle is not be­ing main­tained. On 18 March 2020, the European Se­cur­it­ies and Mar­kets Au­thor­ity (“ESMA”) pub­lished a state­ment about  reg­u­lat­ory for­bear­ance...
17 Mar 20
Bank of England's Dis­cus­sion Pa­per on Cent­ral Bank Di­git­al Cur­rency
Back­ground On 12 March 2020, the Bank of Eng­land (the “Bank”) pub­lished its dis­cus­sion pa­per on Cent­ral Bank Di­git­al Cur­rency, Op­por­tun­it­ies, Chal­lenges and Design (the “Dis­cus­sion Pa­per”). ...
13 Mar 20
Fintech and Cryptoasset De­vel­op­ments in the Budget
On 11 March 2020, the Chan­cel­lor of the Ex­chequer, Rishi Sunak, set out meas­ures the Gov­ern­ment will take to sup­port and de­vel­op the UK’s Fintech and Cryptoasset in­dus­tries, which in­clude the fol­low­ing...