Katie Stephen

Co-Head of the Contentious Financial Services Group, London
Norton Rose Fulbright LLP

United Kingdom
T:+44 (20) 74442431
United Kingdom
T:+44 (20) 74442431
Katie Stephen

Katie Stephen



Katie Stephen is a financial services lawyer based in London.

Katie has over 25 years' experience of advising financial institutions during which she has acted on a wide range of contentious regulatory matters including investigations and enforcement proceedings involving the FCA, PRA, Ofgem, FRC, AIM, ICE, SRA, NCA and HMRC, as well as regulators in other jurisdictions. She regularly advises regulated firms, corporates and senior management on regulatory issues such as market abuse, market disclosures, money laundering, retail mis-selling, consumer credit, conflicts of interest, ESG, corporate governance, systems and controls, individual accountability and notifications.

Katie has extensive experience of supporting clients with skilled person (s.166) reviews and on the conduct of internal investigations including in relation to lessons learned reviews and the design and implementation of redress and remediation programmes. She has also advised the regulator on investigation and enforcement matters and twice been seconded to the FCA as legal adviser to its Regulatory Decisions Committee, the body charged with taking certain authorisation, supervision and enforcement decisions on behalf of the regulator. This has given her a rare and detailed insight into its approach and the enforcement process. Katie is praised by clients as 'an absolute doyen of the FS regulatory arena, with a well-deserved reputation for excellence.' (Legal 500 UK).

Professional experience

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  • Solicitor, qualified in England & Wales
  • Advising the UK branch of a European headquartered financial institution on an investigation by the LME regarding its systems and controls in respect of market abuse. 
  • Advising a UK listed company in relation to a preliminary enquiry by the FCA as to whether the company had breached the Listing Rules and the UK Market Abuse Regulation in respect of a number of public announcements it had made regarding its trading performance; this involved a comprehensive response to the FCA which included a detailed chronology of events surrounding the announcements and a summary of the company's financial reporting processes, following which the FCA closed their enquiry without taking any action against the company.
  • Advising a large accountancy firm in relation to an internal investigation into concerns raised by a number of individuals, primarily relating to culture of the firm; this involved conducting a fact-finding investigation regarding the extent to which there was any substance in the concerns raised and considering recommended next steps to address the findings.
  • Advising a UK based merchant acquirer in response to concerns raised in the media regarding its conduct and activities, and in particular its compliance with the MLRs including the onboarding and ongoing monitoring of clients, and the Payment Services Regulations.
  • Advising a UK listed international travel and tourism company in respect of its responses to two separate enquiries from the FCA and the FRC relating to the company's risk management framework, its process for identifying the principal risks facing the company and the adequacy of its disclosures in its published reports.  Both the FCA and the FRC closed their enquiries with no action being taken against the company. 
  • Advising an individual in respect of a preliminary review by the FCA as to whether that individual had engaged in market abuse in the trading of equities in a certain listed company; this involved the analysis of trading data and communications and the preparation of a detailed response to the FCA, following which the FCA closed their review with no action being taken.
  • Advising a commodities broker in respect of an FCA enforcement investigation into whether the firm conducted market abuse in the trading of metal derivatives during a period of extreme market volatility; this involved assisting the firm in responding to a detailed information request covering trading data, positions, risk limits and HR information.
  • Advising a financial services group headquartered in Africa with a UK branch on an internal investigation into concerns raised by a whistleblower regarding financial and non-financial misconduct spanning a significant period and including a number of conduct and ethics issues.  Our role including advising on communications with the FCA and with the whistleblowers and on various internal governance matters including with regards to the conduct of the investigation and the consideration of the investigation findings by the client's conduct committee in accordance with internal processes.
  • Advising a statutory compensation scheme in relation to a claim for compensation pertaining to advice received regarding a transfer from a defined benefit to a defined contribution pension scheme.  This included advising on the merits of the claim and the possible grounds for judicial review of the scheme's initial decision, as well as reviewing other claims involving some of the same entities to identify any patterns of potentially fraudulent behaviour. 
  • Acting for a global shipping exchange in connection with a wide-ranging information requirement from the FCA regarding an international market abuse investigation conducted by an overseas regulator; this included advice on communications to the FCA to narrow the scope of the requirements, a complex document review exercise and preparation of a substantive response to the FCA.
  • Acting for a UK group in connection with a review of various portfolios of mortgage files.  This included completing a complex legal and regulatory review of a sample of case files, conducting a detailed analysis of contractual obligations and potential liabilities, and advising on communications with the FCA, clients and borrowers.
  • Acting for a large, global, UK-listed corporate group in connection with an urgent request from the FCA that the group cease and desist from any regulated activity for which they are not authorised; this involved advising on communications with the FCA regarding the regulator's serious concerns that the group had been operating an unauthorised collective investment scheme, as well as advising on appropriate steps to take to mitigate any future risk of carrying out unregulated activity.
  • Advising a state owned international bank in relation to an investigation into, amongst other things, a whistleblowing complaint against certain employees of the client and others regarding the payment of "handling fees" and falsification of documents in return for securing customer mortgages.  We also provided advice in relation to the client's reporting obligations under the UK Proceeds of Crime Act.
  • Advising a large accountancy firm in relation to its reporting obligations to the NCA and FCA in respect of potential criminal offences and regulatory breaches committed by a FTSE 100 listed entity that the firm had audited before being made aware of the potential misconduct, specifically in relation to the firm's reporting obligations under POCA, the FCA Handbook and the FSMA Auditors Regulations 2001.
  • Acting for a UK plc in connection with various money laundering issues including consideration of submitting Suspicious Activity Reports to the NCA in accordance with POCA 2002; reporting and disclosures to HMRC and the FCA; announcement to the market of inside information under the Listing Rules and remediation of issues identified.
  • Acting for the UK subsidiary of a African multinational financial services institution in connection with a long-running FCA investigation and enforcement proceedings concerning its anti-money laundering systems and controls over a five year period.  Our role included responding to numerous information requests; attending interviews and negotiating the settlement of the proceedings.  We also secured the discontinuation of the investigation into one of the bank's SMF holders. 
  • Acting for an insurance intermediary which is part of a global insurance group, following urgent intervention action by the FCA in connection with a financial promotion by its appointed representative; this involved advising on communications with the FCA, a customer contact and redress exercise and conducting a complex internal investigation and lessons learned review. 
  • Acting for an individual SMF of a Merchant Bank in connection with a misappropriation of client funds and subsequent communication with the relevant authorities.
  • Advising a UK-regulated global insurer on its notification obligations and communications with regulators and law enforcement in the event of a significant cyber threat/attack. 


Production of information to the authorities - Global Investigations Review - The Practitioner's Guide to Global Investigations, 2021




Publication | Date March 2021