Sara Cody

Counsel, Contentious Regulation, London

"I am a regulatory specialist with over 15 years' experience in helping firms navigate investigations by financial regulators, analysing enforcement trends and helping firms understand and manage drivers of this risk from a UK and global perspective. I support firms through regulatory implementation and investigations processes, and have developed a particular expertise in the FCA’s Consumer Duty. I manage a successful knowledge lawyer team which provides cross-practice support to lawyers in the regulatory and investigations space. "

Overview

Professional experience

Education and qualifications

Published works

Overview

Sara is an experienced contentious regulatory specialist who supports firms through FCA/PRA and internal investigations, regulatory implementation projects and helps firms understand and manage drivers of regulatory risk. Sara’s technical expertise means she is frequently called upon by clients to advise on issues around the FCA/PRA investigatory powers, the consumer duty, conduct risk and individual accountability. 

She has experience of all aspects of regulatory enforcement work and has written extensively on both FCA/PRA enforcement decisions and UK, EU and global enforcement trends. Sara leads the development of Linklaters’ thought leadership and horizon-scanning work in this area, focusing on publications comparing the approach of national financial regulators across the globe to enforcement issues and relevant developments. 

She is frequently called upon by clients to design and deliver bespoke training on the FCA and PRA enforcement process and to advise on the conduct of investigations skills more generally, providing innovative solutions to enable firms to respond effectively.

Sara has developed a particular expertise in the consumer duty. She led the team providing legal advice on consumer duty implementation to a major investment bank and global wealth firm and has provided scoping and implementation advice to firms across a range of sectors, including asset managers, fintechs and hedge funds. Sara supported the Investment Association, AFME, and UK Finance with their responses to the new consumer duty rules and continues to advise their related member forums and working groups. This gives her a keen insight into the challenges these sectors face in terms of their operation of the Duty and unique opportunities to engage with the FCA here. She also designed and delivered Linklaters’ client materials on the consumer duty, which include a monthly webinar series, podcasts and written publications designed to support firms in navigating this new regime.

Sara’s work with trade bodies extends to support with other areas of regulatory policy. She is regularly invited to speak at conferences and member events on both contentious regulation and the consumer duty, and overlaps between the two. 

 

Professional experience

Sara sits on the Consulting Editorial Board of Lexis PSL and writes its regular column on the consumer duty. She also sits on the knowledge forum of a major retail bank.

Prior to joining Linklaters, Sara undertook a variety of commercial litigation, investigations and defendant professional negligence work at another leading City law firm.

Education and qualifications

Sara read Law at Keble College, Oxford University.