Siân Cowan

Associate, Bryan Cave Leighton Paisner

Siân is an Associate in BCLP’s Disputes & Investigations department, based in London. Siân specialises in complex financial regulatory issues for financial institutions and individual members of senior management.

Siân has experience representing clients under regulatory investigation by the FCA, PRA and other government enforcement agencies. She has also worked on several corporate internal investigations concerning bribery and other misconduct.

In addition to her contentious practice, Siân advises clients on compliance policies and procedures covering anti-bribery and corruption, anti-money laundering and counter-terrorist financing. She also has experience of advising clients on their ESG risk, which includes both modern slavery and conducting supply chain due diligence.

Contributed to

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How should senior managers fulfil their personal regulatory duties under the SM&CR in relation to

Q&A

As a result of the conflict in Ukraine and the unprecedented imposition of sanctions which followed, in March 2022, the Financial Conduct Authority (FCA) laid down a clear marker that policing sanctions compliance is a high priority for it and stressed that ‘Where the FCA identifies failings in financial crime systems and controls we can impose restrictions and/or take enforcement action.’ This Q&A considers what this means for senior managers and the standard expected of them in order to discharge their personal regulatory duties under the Senior Managers and Certification Regime (SM&CR) in relation to sanctions compliance.

Financial Services