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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

High rise buildings with sun reflecting

Publications: 27 JULY 2021

The Market Abuse Regulation: the First Five Years

This month marks five years since the Market Abuse Regulation (596/2014/EU) (EU MAR), which has recently been retained into UK law following the expiry of the Brexit transition period (UK MAR), came…

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Sanctions related reporting and compliance obligations for UK financial institutions

Publications: 22 JULY 2021

Sanctions-related reporting and compliance obligations for UK financial institutions

A common question for many sanctions compliance professionals concerns the interplay between regulatory reporting requirements, legal privilege and disclosure obligations to clients. Sarah…

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High rise buildings from the bottom

Blog Post: 08 JULY 2021

UK corporate criminal liability reform

The UK Government has asked the Law Commission to review the law on corporate criminal liability and propose options for reform. Supporters of reform will use recent failures of the UK Serious Fraud…

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Panoramic view of the London skyline

Publications: 27 APRIL 2021

FCA proposes to take enforcement action against an individual relating to "non-financial misconduct"

The UK Financial Conduct Authority (the FCA) is proposing to take enforcement action against an individual, Jon Frensham, relating to "non-financial misconduct".

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Allen & Overy LLP
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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.