Rebecca Dulieu

Senior Associate Norton Rose Fulbright LLP

London +44 207 444 2181

Rebecca Dulieu

An experienced Senior Associate in the Contentious Financial Services Group at Norton Rose Fulbright, Rebecca has over a decade of experience as a financial services lawyer and investigator. Rebecca regularly advises regulated firms, corporates and senior management on strategic mitigation of regulatory risk on a wide range of contentious regulatory issues, from responding to information requirements/enquiries, to urgent intervention and enforcement investigations. She has extensive experience in conducting internal investigations and advising on individual accountability, notification, and reporting obligations. Rebecca has also led on engagements and workshops with financial services clients in relation to AI solutions including co-development and evaluation of specific use cases.

Prior to joining the firm, Rebecca spent nearly five years working in the FCA's Enforcement & Market Oversight Division, initially as an investigator and case team lawyer in the Retail and Regulatory Investigations department, and subsequently as in-house lawyer in the Law, Policy and International department. During this time Rebecca worked on a number of high-profile investigations such as the joint FCA and PRA investigation into Barclays and its CEO Jes Staley (the first case brought by the FCA and PRA under the Senior Managers Regime), and the FCA's investigation into Standard Life Assurance Limited for failures related to non-advised sales of annuities. As a lawyer within the Law and International team, Rebecca advised FCA Enforcement case teams and overseas financial regulators in relation to international law enforcement cooperation and cross-border information sharing.

Before joining the FCA, Rebecca was a lawyer in the financial services regulatory team at RPC LLP where she advised clients on both contentious and non-contentious matters, including defending the FCA's enforcement action in relation to CT Capital and P.P.I complaints handling.

Professional experience

Representative experience

Advising a major banking and financial services trade body on its response to the UK COVID-19 Inquiry, including managing a document review and disclosure process, drafting a senior witness statement, witness preparation and providing strategic advice on engagement with the Inquiry solicitors and trade body members.
Advising a fintech and insurance company in relation to a sensitive, expedited internal investigation into concerns raised by an employee regarding the conduct of an approved senior manager, including non-financial misconduct and disclosure of potentially confidential information.
Advising a Big Four accountancy firm into concerns raised in whistleblowing disclosures relating to conflicts of interest, management conduct and the culture of a business area of the firm.
Advising a reinsurance firm on an internal investigation to consider the extent to which financial guarantee insurance had been underwritten without prior written approval from Lloyd’s, including providing recommendations on lessons learned relating to the firm’s underwriting systems and controls.
Advising a large UK loan administrator on a complex file review into second charge lending practices to assess compliance with applicable consumer credit law and regulation across an extended period. This subsequently included advising on comprehensive redress and remediation and preparing communications to the FCA, the clients and borrowers.
Advising a global maritime industry body in responding to a wide-ranging FCA information requirement relating to an international market abuse investigation conducted by an overseas regulator, including negotiating a narrower scope of requirement, managing a complex document review exercise and preparation of a substantive response to the FCA.
Advising an insurance firm following a whistleblowing disclosure relating to twenty separate issues of firm governance, non-financial resources and management information. This included conducting a comprehensive internal investigation, advising on regulatory notifications and managing an exercise to determine the extent to which recommendations following the internal investigation had been adequately implemented.
Advising 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 concerns that the group had been operating an unauthorised collective investment scheme.
Advising an insurance intermediary, part of a global insurance group, in relation to its response to urgent FCA supervisory action in connection with a financial promotion issued by its appointed representative. This included negotiating with the FCA to secure additional time to respond and alternative wording to the requirement, advising on a comprehensive customer contact and redress exercise, subsequently conducting an internal investigation in connection with its financial promotions approval process and lessons learned review.
Advising a global algorithmic digital assets trading firm on its response to an FCA compelled information requirement in connection with an overseas regulator’s investigation.
Acting for the UK subsidiary of an 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. This included negotiating the settlement of the proceedings.
Advising a Big Four 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.
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.
Advising a commodity derivatives trading firm regarding its dawn raid policy, redrafting the policy and corresponding training materials focussing on FCA, PRA & CMA investigatory powers.
Advising a broad range of financial services firms on AML queries, including customer due diligence obligations, intra-group sharing of suspicious activity reports, risks of committing money laundering offences or regulatory breaches, self-reporting/notification requirements in accordance with FCA, PRA, Lloyds’ and POCA reporting obligations.