Rowena Wisniewska Sethi

Barrister, 4-5 Gray’s Inn Square

Rowena specialises in Financial Services Law and Regulation and has around 10 years experience in the Enforcement Legal Group at the (then) Financial Services Authority and its successor the Financial Conduct Authority. Rowena has been involved in a wide range of regulatory cases and litigation in the Upper Tribunal (Tax and Chancery Chamber), the High Court, Court of Appeal and Supreme Court at the FSA, FCA, the Treasury Solicitor and Government Legal Department. Rowena originally qualified as a solicitor in 2001 and worked in private practice before joining the Treasury Solicitor. During her time in Central Government she was instructed in general private law litigation, immigration and other judicial review matters. Rowena has particular expertise in providing regulatory investigation support, interview planning, advice on regulatory breaches and contested authorisation and registration matters, included contentious fitness and propriety assessments.

Rowena has a particular interest and expertise in Defined Benefit Pension Transfers, Change in Control notifications, Cryptocurrency Registrations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, contested applications for authorisation and approval and advising on fitness and propriety assessments under the Senior Managers and Certification Regime. She also has experience in Skilled Persons reviews, Bribery and Corruption Investigations and Systems and Controls regulatory matters.

Admitted to the Roll of Solicitors in 2001. Year of call 2007

Contributed to

1

The FCA Consumer Duty–application to pension providers and pension schemes

Practice Notes

FORTHCOMING CHANGE: On 29 June 2026, the FCA published CP26/23 Consumer Duty: scope and proportionality, proposing targeted changes to its rules and non-Handbook guidance to clarify the scope of the Consumer Duty and support its proportionate application. The proposals include generally limiting the Duty to retail market business involving UK-resident customers, clarifying its application to activities and firms in distribution chains, and refining expectations concerning reliance between firms, vulnerable customers, information gathering, outcomes monitoring and board reporting.The Financial Conduct Authority’s (FCA) Consumer Duty places an increased emphasis on firms putting the needs of their customers first, by creating a requirement that they act to deliver good outcomes for retail consumers.The Duty came into force on 31 July 2023 for new and existing products or services that are open to sale or renewal. On 31 July 2024, the Duty came into force for closed products or services. This presents a development for pension product providers and those who manage legacy

Pensions