Polly’s track record includes:

• Conducting a cross-border (UK/US) complex trading investigation for an investment bank following allegations of front-running raised by a whistleblower;
• Conducting an internal investigation for an international banking group following allegations brought by a whistleblower of inappropriate disclosure of information about one client to another client;
• Representing a former senior manager in relation to an FCA enforcement investigation concerning allegations of market manipulation and market abuse;
• Representing a senior manager in connection with an FCA enforcement investigation into alleged pensions advice failings;
• Representing an individual client in an FCA investigation into alleged insider dealing and destruction of relevant evidence;
• Conducting an internal investigation for a leading international bank following allegations of corrupt hiring practices raised by a whistleblower;
• Advising various firms in receipt of correspondence from their FCA supervisors in context of proposed uses of own-initiative powers (OIREQs, OIVOPs etc);
• Conducting an internal investigation for a UK subsidiary of an international bank following a whistle-blower’s allegation of serious failings in the firm’s financial crime prevention framework;
• Acting for a senior banker in one of the first enforcement investigations conducted jointly by the PRA and the FCA;
• Leading a large team of lawyers and forensic accountants conducting a complex internal investigation into allegations of financial irregularities raised by a whistleblower in the asset-management sector;
• Representing an insurance company owned by a large global insurance group on an FCA enforcement action into alleged mis-selling across five EU jurisdictions;
• Acting for a former director of an asset management firm on a ‘dual track’ criminal and civil FCA investigation relating to alleged financial crime control failings; and
• Conducting three internal investigations for a large global bank in relation to allegations relating to culture and conduct that had been raised by whistle-blowers.

Polly’s experience includes acting on matters involving:

• Breaches of client assets (CASS) rules;
• Breaches of POCA;
• Breaches of the Money Laundering Regulations;
• Bribery and extortion
• Culture and conduct (including ‘non-financial misconduct’);
• Financial crime systems and controls breaches;
• Financial reinsurance;
• FX sales practices;
• Governance;
• Inappropriate disclosure of confidential information;
• Insider dealing;
• Market manipulation and market abuse;
• Mis-selling (insurance, pensions and mortgages);
• Mortgage arrears management;
• Non-disclosure of relevant information to regulators;
• Outsourcing oversight failures;
• Pensions mis-selling;
• Protection of whistle-blowers;
• Risk management failures / systems and controls breaches; and
• Trader mis-marking.