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Sarah Hitchins



Hitchins Sarah
Sarah Hitchins



Sarah specialises in representing firms and senior individuals involved in internal and regulatory investigations.

She has significant experience of advising on UK and cross-border investigations involving a broad range of issues, including market abuse, insider trading, financial crime, cyber and data security breaches, individual accountability, operational resilience, misselling, systems and controls failures, whistleblowing, cultural issues and non-financial misconduct.

She has also represented a number of clients in regulatory investigations concerning compliance with UK listing and Takeover Code requirements. Sarah frequently represents clients that are involved in regulatory investigations, including investigations by the UK Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA), where she previously completed a secondment in its Enforcement Division.

In addition to her investigations experience, Sarah has also advised over 75 firms (including banks, building societies, insurers, asset and fund managers) on the implementation of the UK Senior Managers and Certification Regime (SMCR), as well as a variety of post-implementation issues. In particular, Sarah has significant experience advising clients on the individual accountability aspects of investigations, including assessments of fitness and propriety and potential breaches of the FCA and PRA Codes of Conduct.

Sarah was previously selected by Global Investigations Review (GIR) as one of the top 100 women in investigations.

News & insights

Reflection of clouds in building windows

Publications: 25 FEBRUARY 2021

A new perspective on the FCA's focus on market abuse

Sarah Hitchins considers the FCA's commentary on market abuse risks in the light of the Covid-19 pandemic, as well as recent enforcement activity in this area.

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A group of modern high-rise offices and skyscrapers

Publications: 19 NOVEMBER 2020

FCA takes first enforcement action for breaches of Short Selling Regulation

In October 2020 the FCA issued a Final Notice to Asia Research and Capital Management Ltd (ARCM). 

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Publications: 19 OCTOBER 2020

The FCA’s 5 conduct questions: Translating theory to practice

The FCA has published its “Five Conduct Questions” report for 2020, highlighting key observations and issues with respect to firms’ conduct and culture programmes.

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Accountability regime for senior managers of financial institutions in Singapore

Publications: 29 SEPTEMBER 2020

Accountability regime for senior managers of financial institutions in Singapore

The MAS has issued its finalised Guidelines on Individual Accountability and Conduct, which will come into effect on 10 September 2021.

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Allen & Overy LLP
One Bishops Square
E1 6AD

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Admitted as a solicitor, England and Wales, 2011


BA and MA, Law, University of Cambridge (Gonville & Caius College), 2008

LPC, BPP Law School (London), 2009

Published work

Regular contributor to Practical Law Company’s contentious regulatory materials.

Editor of Allen & Overy’s Investigations Insight blog, which focuses on the latest trends, risks and developments in financial services investigations.