Following the Rules

Special episode: How to navigate a dawn raid with the SFO's Emma Isaac and Simmons & Simmons' Camilla de Silva

Today’s episode is part of a special series of Following the Rules produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape.
The series offers practical insights to help financial services firms navigate legal, regulatory, technological, and cultural change.
In this episode, we’re diving into one of the most intense moments a business can face - a dawn raid.
When Nick Ephgrave took over as Director of the UK Serious Fraud Office in 2023, he’s pledged “swifter action and more dawn raids” - a clear signal that the agency is refocusing on proactive, visible enforcement.
But what does a dawn raid actually look like in practice? How should firms respond when investigators appear unannounced at the door? And how can businesses prepare, both legally and culturally, for such a high-pressure event?
To answer these questions, we’re joined by two experts on the topic:
Camilla de Silva, who spent over five years at the SFO, rising to Joint Head of the SFO’s Fraud, Bribery and Corruption division, before joining Simmons & Simmons in 2020 as a Partner in its Disputes and Investigations group. Since 2023, she has lead Simmons & Simmons’ Corporate Crime and Global Investigations group; and,
Emma Isaac, who worked as criminal legal adviser before moving to the SFO in 2013. In February, she became a member of the agency’s senior leadership team when she was appointed Joint Head of the SFO’s Fraud, Bribery and Corruption division.
Together, they discuss how enforcement dynamics are shifting, what mistakes companies tend to make under pressure, and what practical steps legal and compliance teams can take today to be ready if the SFO comes knocking.
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Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...

Graham Kent, Deutsche Bank's Group Chief Compliance Officer, on the compliance challenges shaping the industry’s future

Today’s guest outlines how the accelerating pace of regulatory change poses significant challenges for global financial institutions. He highlights that fragmentation can create a complex landscape for banks’ compliance divisions, and underscores the benefits of adopting a more coordinated, risk-based approach to rulemaking.
He also discusses how the industry could best evolve the traditional three lines of defence model, how banks can better anticipate risks and how banks and regulators can collaborate to achieve an effective balance between protecting markets and promoting growth.
Graham Kent’s career spans three decades and includes seven years as a lawyer at Clifford Chance. He joined Deutsche Bank’s legal department in 2006. He has since held several senior roles across the bank’s legal and compliance divisions before becoming its Group Chief Compliance Officer in 2024.
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Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...

Special episode: How to cut red tape for financial leaders while raising conduct standards with Penny Miller and Andrea Finn of Simmons & Simmons

Today’s episode is part of a special series of Following the Rules produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape.
The series offers practical insights to help financial services firms navigate legal, regulatory, technological, and cultural change.
In this episode, we explore two closely-linked developments set to reshape the compliance agenda: reforms to the UK’s senior managers regime, and the FCA’s new rules on toxic workplace behaviour, which will bring bullying, harassment, and discrimination within the scope of regulatory misconduct from 2026.
So, what do these changes mean for senior managers and their teams? How can firms strike the right balance between cutting red tape and maintaining strong accountability? And how should legal, compliance and HR functions prepare for regulator’s growing focus on culture and non-financial misconduct?
Joining me to discuss these questions are:Penny Miller, who leads Simmons & Simmons' UK business and is a partner in its Financial Services Regulatory Group, advising global banks and asset managers on complex UK and cross-border regulatory issues and, Andrea Finn, a partner who heads the UK Employment and Pensions Group at Simmons & Simmons, specialising in employment and conduct matters, with extensive experience helping firms navigate the overlap between regulatory and employment law.
---Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...

Special episode: How to master compliant voice surveillance in financial services with Smarsh’s Ryan Kahan

Today’s episode is a special one produced in association with Smarsh, a technology firm providing global financial institutions with the tools to capture, store, and monitor their communications.
It’s part of a new Following the Rules series providing practical guidance to help financial services firms navigate legal, regulatory, technological, and cultural change.
In this episode, we look at a hot-button issue for regulators on both sides of the Atlantic: how banks and investment firms monitor voice communications. Even in an era of instant messaging, the most sensitive deals are still struck over the phone. And that makes voice communications a prime focus for watchdogs worried about misconduct and recordkeeping failures.
I’m joined by Ryan Kahan, the executive vice president of voice interactions at Smarsh, who has spent decades helping financial institutions navigate the complexities of voice recording and surveillance. We discuss why regulators are ramping up pressure on firms to capture and store calls, the common mistakes banks make when trying to upgrade their systems, how new technology could transform the field, and what practical steps firms should be taking now to stay ahead.
 
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Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...
 

Special episode: How to future proof your business with Charlotte Stalin and Sarah James of Simmons & Simmons

Today’s episode is a special one produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape.
It also forms part of a new Following the Rules series providing practical, actionable guidance to help listeners and the financial services firms they work for navigate legal, regulatory, technological, and cultural change.
In this episode, we turn to the future of work – an area moving rapidly up the agenda. A 2024 survey by the Bank of England and the FCA found that 75% of UK-regulated firms are already deploying or trialling AI and machine learning, particularly in areas like anti-money laundering, and fraud detection. By 2025, firms are beginning to explore more sophisticated and complex use cases.
So how will AI reshape the role of legal and compliance teams in financial services? What steps can organisations take to future-proof these functions as innovation accelerates? And what are the risks of failing to adapt?
Joining us to share their insights are:
Charlotte Stalin, the head of Simmons & Simmons’ financial institutions sector, who advises leading global investment firms and banks on financial services regulation, having joined the firm in 2006.
Sarah James, a Partner at Simmons & Simmons, who since 2016 has also led the firm’s flexible legal resource business, Adaptive, as its Global Head.
Short on time? You can read the episode highlights on the FT's Banking, Risk and Regulation...

FCA’s Charlotte Clark on the firms ‘over-interpreting’ Consumer Duty, how the watchdog plans to help City firms navigate compliance, and its role in supporting firms through rapid AI adoption

Today’s guest discusses how some wholesale financial institutions may be unnecessarily “gold-plating” their efforts to comply with the Financial Conduct Authority’s Consumer Duty regime.
She details how the regulator plans to both clarify and simplify its expectations of all firms subject to the far-reaching ruleset.
She also discusses the FCA’s plans to help firms, both large and small, navigate the rapid deployment of AI tools across financial services and explains why inclusive product design is important for firms to get right.
Charlotte Clark’s career includes stints overseeing policy on various aspects of pensions regulation at HM Treasury and the Department for Work and Pensions, as well as four years as director of regulation at lobby group the Association of British Insurers. She joined the FCA in November 2024 to lead its work on consumer strategy, and broader policy affecting firms across all sectors as the watchdog’s director for cross-cutting policy and strategy.
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Short on time? You can read the episode highlights on the FT's Banking, Risk and Regulation

Special episode: How to track non-financial misconduct within your business with Smarsh's Shaun Hurst and former Standard Chartered surveillance chief Emily Wright

Today’s episode is a special one produced in association with Smarsh, a technology firm providing global financial institutions with the tools to capture, store, and monitor their communications.
It also marks the launch of a new Following the Rules series providing practical, actionable guidance to help listeners and the financial services firms they work for navigate legal, regulatory, technological, and cultural change.
We’re kicking off with a deep dive into non-financial misconduct - a growing area of regulatory focus. The UK’s Financial Conduct Authority now considers toxic workplace behaviour, such as bullying, harassment, and discrimination, to be conduct that could impact a person’s fitness for regulated roles and signal broader cultural failings. From 2026, the FCA will begin supervising serious cases more closely.
So how can firms of all sizes effectively detect, respond to, and minimise non-financial misconduct within their businesses? How do you define what counts as serious bullying or discrimination? And how can organisations ensure change is meaningful, not just a box-ticking exercise?
Today’s guests are experts in the subject.
Shaun Hurst is Smarsh’s Principal Regulatory Advisor, with a background in managing technology for Citigroup’s security and investigations teams in Asia-Pacific and Europe, the Middle East and Africa.
Emily Wright is a compliance and conduct consultant with over 20 years' experience, including overseeing compliance and surveillance programmes at financial services giants Standard Chartered, JP Morgan, and ICAP.

Mark Watson, SVB’s former management governance head, on the crisis policymakers, regulators, and financial institutions are sleepwalking into and how to avoid it

Today’s guest outlines where governments and financial regulators are going wrong in their supervision of the sector.
He details where he sees potentially systemic risks mounting and he explains what banks, financial institutions and their supervisors can do now to prevent a significant blow-up from occurring on their watch.
Mark Watson is a governance and risk expert whose three-decade career includes stints advising financial institutions on governance and non-financial risks on behalf of consulting giants McKinsey and EY. In 2022, he joined Silicon Valley Bank, to lead a redesign of its management decision-making as its head of management governance. Since the bank’s collapse in 2023, he has been advising financial institutions on corporate governance, risk management, and financial services regulation as the founder of Portcullis Consulting.

FMSB CEO Myles McGuinness on his plans to help the City tackle non-financial misconduct, and bolstering the standard setters' future in an increasingly polarised world

Today’s guest explains why global standards for financial conduct could help counter the risk of rising regulatory fragmentation - providing, as he puts it, “the glue to hold diverging rule books together.”
He outlines how a robust governance framework could help financial institutions better tackle toxic workplace behaviour. He explains why he believes a central repository for authenticated data may be key to fighting AI-generated fakes.
And he opens up about the Financial Markets Standards Board’s ambitions to expand its global footprint and its membership.
Myles McGuinness’s 30-year career includes two decades - and several senior roles - at UK lender NatWest Markets. He spent two years establishing the bank’s capital markets business in Europe as its EMEA head of Financing and Risk Solutions before leaving in 2021 to lead the FMSB as its CEO.

Jillien Flores of the Managed Funds Association on how rulemakers can best rethink overly-onerous regulations for alternative asset managers, and the "misguided" policies they should avoid

Today’s guest calls on regulators and policymakers to stop seeking to regulate alternative asset managers like they’re banks.
She details how policymakers can best rethink the regulatory framework for the non-bank sector to benefit not only alternative asset managers but also the financial sector more broadly.
And she explains how a push to harmonise the rulebooks between competing financial hub could also help with a broader push to bolster jurisdictional competitiveness.
Jillien Flores is a regulatory affairs specialist whose 17-year career includes seven years at government relations firm Porterfield, Lowenthal, Fettig & Sears where she helped to shape several of the US’s landmark regulatory response to the 2008 financial crisis, including the Dodd-Frank Wall Street Reform 
She spent six years advocating on regulatory issues for asset manager Vanguard before leaving in 2021 to join the Managed Funds Association, a trade group representing the world's biggest hedge funds, where she now serves as Chief Advocacy Officer.
 
---Short on time? You can read the episode highlights on the FT's Banking, Risk and Regulation