Steven Francis

Insurance & Financial Services

Steven advises all sorts of participants in the insurance and financial service sector — general and life insurance carriers and intermediaries, including Lloyd’s entities; asset managers, investment platforms and those providing custody services; pension providers; and payment and electronic money firms.

He assists firms in getting authorised, complying with conduct and prudential rules, and managing their dealings with regulators including the FCA and the Bank of England / Prudential Regulation Authority (PRA). He also advises on new technologies such as artificial intelligence (AI), distributed ledgers and token-based products. 

Steven advises on the de-authorisation of firms, and on their winding-up. In this regard he often works with insolvency practitioners.

Advisory & Regulatory Compliance

Steven’s compliance work takes place against a backdrop of current or anticipated regulatory intervention. He has advised on all the major issues that have faced the insurance and financial service sectors — including mis-selling of pensions, payment protection insurance (PPI), interest rate swaps and insurance products; benchmark rigging of the London Interbank Offered Rate (LIBOR), foreign exchange market (FX) and metals; client money failures; anti-money laundering (AML) failures; sanctions breaches; data loss; product governance failures; and failures in leadership and board effectiveness.

Internal Investigations & Regulatory Interventions

Much of Steven’s work involves internal investigations — identifying for firms what has happened, what the consequences are, what corrective measures are needed, and what disclosures to make to authorities. This addresses the fact that many insurance and financial service firms are keen to avoid the fines and reputational damage that are the near-certain consequence of an FCA enforcement case; so when issues arise, they seek Steven’s support to help them investigate, self-report to the FCA if appropriate, and deal with redress and remediation.

Steven leads these investigations and advises on the regulatory interventions, including negotiations and disclosures; procedures of crime reporting, redress and remediation programmes; and defense of Financial Ombudsman Service cases. Besides the PRA and FCA, he negotiates with European regulators including OLAF as well as the U.S. Securities and Exchange Commission and Department of Justice.

Litigation & White Collar Defense

Many FCA cases are brought as dual civil/criminal cases, so it is important to have experience and skill in both areas. Steven’s experience includes both prosecuting and defending criminal and disciplinary charges. He is a skilled white collar and governmental investigations attorney, and has acted in cases involving bribery, fraud, tax evasion and cartel infringements. Steven has handled disciplinary and criminal investigations for firms and their directors and senior managers. He has also represented individuals accused of offences of violence including murder.

Steven has helped to settle cases not only involving the FCA, but also the City of London Police; Serious Fraud Office, Ministry of Defense, the U.S.’s Office of Foreign Assets Control, Germany’s BaFin and Luxembourg’s CSSF.

Personal Interests

In what little free time Steven has (he has two young boys), he cycles and enjoys writing.