Sara Cody | Lawyers | Linklaters

Admissions

UK (England & Wales)

Services

Financial Regulation Group

Testimonial

"I provide clients with clear, pragmatic support in navigating investigations by financial regulators and expert advice on the application of the FCA’s Consumer Duty. "

Overview

Sara is an experienced contentious regulatory specialist who supports firms through FCA, PRA, and internal investigations, regulatory implementation projects and broader supervisory engagement. She helps firms identify and manage drivers of regulatory risk from both a UK and global perspective, working with a range of regulated firms including the UK’s largest investment and retail banks, asset managers, fintechs, private wealth and payment institutions.

Sara has deep expertise in all aspects of regulatory enforcement, conduct risk, individual accountability and the regulation of retail products. She has written extensively on FCA/PRA decisions and UK, EU and global enforcement trends. Sara leads Linklaters’ thought leadership and horizon‑scanning in this area, including cross‑jurisdictional analysis of how national financial regulators approach enforcement.

Clients frequently instruct Sara to design and deliver bespoke training on the FCA and PRA enforcement process and on investigations skills more generally. She is known for providing clear, pragmatic and innovative solutions that enable firms to respond effectively to regulatory scrutiny.

Sara has built a particular market profile for her work on the FCA’s Consumer Duty, advising several firms on their implementation and ongoing compliance programmes. She supported several trade associations with their responses to the draft Consumer Duty rules and continues to advise their member forums and working groups. Sara has a detailed understanding of the sector‑specific challenges the Duty presents and is involved in stakeholder engagement as part of the FCA’s ongoing review of the application of the Consumer Duty to wholesale firms.

Experience

Her Consumer Duty client work includes:

Supporting firms (including private banks and payment firms) with implementation and ongoing compliance.
Advising wholesale firms on complex scoping and implementation issues.
Advising firms on their approach to, and drafting of, annual board reports.
Advising on business‑as‑usual compliance across sectors including investment banking, asset management, private wealth and fintechs.

Sara has a specific interest in the interaction between the Consumer Duty and emerging areas of retail financial regulation, including buy now pay later products, cryptoassets, targeted support, sustainability rules and the new CCI regime.

Beyond the Office

Sara’s experience and insights into regulatory investigations, enforcement and the Consumer Duty mean she is regularly asked to contribute to industry organisations and regulatory initiatives.

Her involvement has included:

contributing to work undertaken by the Association for Financial Markets in Europe, UK Finance and The Investment Association; and
speaking regularly at industry and client seminars on topics including the Consumer Duty, investigations and enforcement, culture and conduct, SMCR and non-financial misconduct.

Sara is a member of the Consulting Editorial Board of Lexis PSL.

Sara was the Co-Chair of Linklaters’ award-winning Social Mobility Network between 2021 and 2025.

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

Recognition

Sara is listed as a ‘Leading Associate’ in Legal 500.

Education, Qualifications and Languages

Sara read Law at Keble College, Oxford University. She gained a distinction on the Legal Practice Course at Nottingham Law School.

Overview

Experience

Her Consumer Duty client work includes:

Supporting firms (including private banks and payment firms) with implementation and ongoing compliance.

Advising wholesale firms on complex scoping and implementation issues.

Advising firms on their approach to, and drafting of, annual board reports.

Advising on business‑as‑usual compliance across sectors including investment banking, asset management, private wealth and fintechs.

Admissions

Services

Overview

Experience

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Beyond the Office

Recognition

Education, Qualifications and Languages

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Overview

Experience