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Jodi Norman



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Jodi Norman



Jodi Norman heads Allen & Overy’s Middle East Financial Regulatory team and advises on regulatory matters affecting the wholesale markets and financial market infrastructure, advising global investment banks and other financial institutions.

Jodi is experienced with assisting financial institutions meet their governance and regulatory organization obligations, including with respect to material outsourcing arrangements (both third party and intra-group). Jodi’s experience includes advising and drafting material outsourcing agreements compliant with UK SYSC requirements, MiFID organizational requirements and EBA Guidelines on Outsourcing. She has advised on outsourcing arrangements in the ADGM and the DIFC, in each case drawing on the IOSCO Principles on Outsourcing of Financial Services and other international standards. She is particularly experienced in putting in place outsourcing and other reliance arrangements in the context of intragroup outsourcing of financial crime compliance matters (including pursuant to regulator mandated remediation programs).

In addition, Jodi has advised clients in the design, establishment and documentation of a number of complex intra-group outsourcing arrangements in the context of the UK’s withdrawal from the European Union. These arrangements are material outsourcings, involving the outsourcing of a financial services and non-financial services activities. These arrangements comply with multiple regulators’ outsourcing requirements and needed to be flexible enough to reflect the intragroup nature of the services being provided – experience that will be directly relevant to FAB’s current project. Jodi has published a number of client briefings on regulated outsourcings, most recently the impact of the EBA Guidelines on Outsourcing on firms’ Brexit outsourcings: Final EBA Outsourcing Guidelines: Impact on Firms’ Brexit Contingency Plans

Jodi holds a CISI Level 6 Diploma in Investment Compliance, a qualification developed specifically for compliance professionals.

In 2020, Jodi was recognized in Global Banking Regulation Review’s “45 under 45.”

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Banking and Finance



11th Floor, Burj Daman Building, Al Mustaqbal Street, Dubai International Financial Centre
PO Box 506678

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Admitted as a lawyer, Ireland, 2018

Admitted as a lawyer, England and Wales, 2009


BA PPE (Hons), Politics, Philosophy and Economics, University of York/University of California, Santa Cruz, 2005

Level 6 Diploma in Investment Compliance, 2014

CISI Certificate in DIFC Rules & Regulations, 2012

CISI Islamic Finance Qualification, 2012

Other noteworthy experience


  • SoftBank on an ADGM material outsourcing, including the provision of Approved Persons, Recognized Persons and other financial services activity
  • On the application of the UAE Central Bank’s Corporate governance Regulations, including the application of requirements on UAE branches of foreign banks
  • Establishing and documenting the global outsourcing arrangements for Ebury, a payments services group, in respect of financial crime compliance outsourcing
  • Documenting the intragroup outsourcing arrangement for TP ICAP between certain trading venues and related group data reporting entities, in compliance with the requirements of the EU MiFID organization requirements
  • A number of banks and investment firms on the application of the recently issued EBA Outsourcing Guidelines (both on an intra-group and a third party basis)
  • Man Group on outsourcing certain fund administration activity from Ireland to the UK
  • Nomura on establishing and documenting a bespoke trade control framework and bank control framework, meeting European, U.K. and German material outsourcing requirements
  • RBS on establishing a bespoke trade control framework and bank control framework, meeting European, U.K. and Dutch material outsourcing requirements
  • ING Group on establishing and documenting its material outsourcing arrangements