Rebecca Dulieu

Senior Associate Norton Rose Fulbright LLP

London +44 207 444 2181

Rebecca Dulieu

Rebecca Dulieu is a financial services lawyer based in London. She advises clients on contentious matters, including regulatory intervention and enforcement proceedings in relation to both the retail and wholesale markets.

Prior to joining the firm, Rebecca spent more than four 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 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 in relation to CT Capital and P.P.I complaints handling, advising insurers on their regulatory exposures in connection with regulated complaints, and conducting Board Effectiveness Reviews for insurance intermediaries and Lloyds managing agents in respect of their compliance with Lloyd's, FCA and PRA obligations.

Professional experience

Representative experience

Advising a large accountancy firm in relation to an internal investigation into concerns raised by a number of individuals, primarily relating to the 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.
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.
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.
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 a global industry body 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.
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.
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.