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 Sarah Brook
Partner

Sarah Brook

Languages
  • English

Sarah carries out both regulatory contentious and advisory work for a range of clients within the financial services sector, with a focus on firms that operate in the insurance market.  She assists with a range of regulatory and commercial issues affecting insurance market participants including regulatory perimeter queries; governance and conduct of business requirements; regulatory aspects of corporate deals; distribution models; product development, and authorisation applications.  In recent years Sarah has been particularly focussed on Brexit related issues and has drawn on the close relationships she has developed with counsel across the EEA to support both domestic and EEA insurers and brokers to navigate the post-Brexit world. 

From a contentious perspective Sarah has a broad range of experience in assisting clients in their relations with the Regulators, with a view to mitigating regulatory intervention.  This includes advising on supervisory reviews, regulatory enforcement actions, regulatory notifications, internal investigations, complaints brought before the Financial Ombudsman Service, and remediation exercises.  In addition, Sarah has experience of assisting on a Competition and Markets Authority market investigation following an FCA referral.
 

Relevant experience

  • Numerous (re)insurer and broker clients on Brexit related matters, including contingency planning and the development and implementation of structures designed to ensure the smooth continuation of business activities.
  • A large investment consultancy and fiduciary management firm with its response to the FCA's proposal to refer to the sector to the CMA for a full market investigation.  Following the referral, the first of its kind, Sarah worked closely with the client throughout the market investigation and was heavily involved in drafting responses to working papers, provisional findings and the CMA's draft Order.
  • A global insurer to implement its post-Brexit reorganisation, including advising on two PRA authorisation applications and a related Part VII insurance business transfer.
  • Strategic guidance on regulatory notifications and the governance of an internal investigation to an insurance broker that had detected potential internal fraudulent activities. Conducting a detailed investigation into the potential frauds and likely root causes.  
  • A healthcare provider on the development of an innovative form of healthcare provision, including liaising with the FCA on perimeter issues, drafting the product terms and conditions and assisting with the development of marketing and training materials.
  • An individual on a highly complex FCA enforcement action, including providing strategic advice on connected matters involving a foreign regulator and a number of UK government agencies.
  • A multi-national consultancy and investment manager on the contractual architecture underpinning a multi-national pension solution offering, including drafting and negotiation.

Education

2009 – LPC, BPP Law School, London

2008 – LL.M., University of Leicester, Leicester

2007 – LL.B., Durham University, Durham