Sarah Thompson is Head of our Financial Regulation Group, and is also Head of our cross-disciplinary ESG Group.

Sarah has experience in advising a broad range of clients on financial regulation matters and is admitted to practice in Northern Ireland, Ireland and England & Wales.

Sarah advises on Central Bank of Ireland authorisation processes, perimeter issues, ongoing compliance with conduct of business and other requirements (with a special focus on ESG matters and on the Individual Accountability Framework and the Senior Executive Accountability Regime, IAF/SEAR), and financial services M&A.

Prior to joining Arthur Cox, Sarah worked in London as a member of the Financial Regulation Group of Linklaters LLP and a partner in the Financial Services Regulatory team of Kirkland & Ellis International LLP.

Regulatory change and strategy: Advising numerous banks, investment firms, payment services firms, proprietary traders and market infrastructure providers on regulatory reform initiatives including in respect of CRD VI, MiFID II, operational resilience, digital assets regimes and ESG regimes.

Cross border and multi regulator frameworks: Advising local and international banks, investment firms, asset managers and financial market infrastructure on their Irish, UK and EU regulatory structures and on managing divergent regulatory frameworks across multiple jurisdictions. This includes supporting clients in responding to evolving global legal and compliance frameworks.

Contentious and supervisory regulatory matters: Advising clients on regulatory investigations and supervisory engagement.

Financial sector corporate and restructuring activity: Advising on group reorganisations of banking and investment firm groups, acquisitions and disposals of regulated businesses (including by private equity sponsors), change of control and authorisation processes and special administrations and resolution planning for investment firms and other regulated entities.

Governance: Working across the banking and asset management sectors with Boards, non-executive directors and executive management teams, advising on the design of governance structures and systems and controls.

Relevant Experience

  • Assisting clients with applications for authorisation as MiFID investment firms and electronic money institutions
  • Advising a number of leading US private equity houses on their obligations under MiFID, SFDR and IFR/IFD
  • Assisting a number of global financial institutions in tracking ESG developments and preparing for compliance (at firm and product levels)
  • Advising the Liquidity and Sustainability Facility (designed by the United Nations Economic Commission for Africa (UNECA), in collaboration with Afreximbank) on its inaugural repo transaction with Citi
  • Delivering training to client legal and compliance teams on various matters including governance matters, IAF/SEAR and sustainable finance regulation
  • Working with a number of Irish credit institutions to prepare for the introduction of the revised Irish client asset regulations
  • Advising Montagu and Hg on financial services regulatory matters connected to their investments in Waystone
  • Advising Global Shares plc on financial services regulatory matters connected to its acquisition by JP Morgan