Image of Chloe Barrowman

Chloe Barrowman

Professional Support Lawyer

Chloe specialises in financial regulation, advising on a broad range of issues affecting financial market participants, including banks, financial market infrastructure providers, investment funds and financial technology companies.
Chloe works with market associations and other industry bodies to support industry responses to legislative and regulatory reform. She writes client briefings on key regulatory developments, helping clients and internal teams to keep up-to-date and navigate regulatory change. Recent areas of focus include the UK's Smarter Regulatory Framework, MiFID II, bank ring-fencing, recovery and resolution and ESG and corporate sustainability legislation. Chloe also has experience in finance, derivatives and capital markets matters.


Representative matters

A global financial market infrastructure provider in connection with U.K. regulatory issues.

A payment services firm in connection with its application for authorisation with Abu Dhabi Global Market.

A Middle Eastern country on the establishment of a new legal regime within its territory.

The UK government on proposals for regulatory accountability, restraining the regulators so that they act predictably and consistently, and in accordance with newly generated case law.

A global company on its multi-billion dollar facilities agreements and commodities hedging arrangements.*

An international shipping conglomerate on an amendment and restatement of its facility agreement.*

A private equity fund in connection with its acquisition of two UK companies and accession to a facility agreement.*

A conglomerate in connection with a margin loan facility.*

A sovereign in connection with its foreign exchange hedging arrangements.*

A sovereign in connection with various multi-billion dollar bond issuances, including an exchange offer, new notes issuance and combined new notes issuance and switch and tender offer.*

A national development bank in connection with its €1bn Green Bond.*

Pro bono

Advising investors in London Capital & Finance plc on a range of issues, including: (i) a judicial review of the Financial Services Compensation Scheme's decision not to compensate the majority of bondholders following LC&F's collapse in 2019 (R v Financial Services Compensation Scheme Limited [2021] EWHC 760 (Admin)); and (ii) representations to government in relation to the ad hoc compensation scheme ultimately established under the Compensation (London Capital & Finance plc and Fraud) Act 2022.

Published Work

  • Donegan T., Swil J., Johnston T., Matthews J. and Barrowman C., (2023) “The Effect of Contractual Unfairness Under the Consumer Rights Act 2015 on the Transferability of Bonds Following the High Court's Decision in R. (Donegan) v Financial Services Compensation Scheme”, London: JIBLR
  • Donegan T. and Barrowman C., (2023) “London Capital & Finance Plc—Was It a Collective Scheme?”, London: JIBLR
  • Donegan T., Swil J. and Barrowman C., (2023) “The UK's Last Asserted Francovich Claim? On the Regulation of Non-transferable Bonds and the Legal Backdrop to the UK Government's Compensation of London Capital & Finance Investors”, London: JIBLR
  • Letherman S., Donegan T. and Barrowman C., (2023) “London Capital & Finance Plc—A Spotlight on the ISA Regulations and the Need for Reform”, London: JIBLR


  • “Key lawyer” for Financial Services: Contentious, Legal 500 UK, 2023
  • “Highly Recommended”, FT European Innovative Lawyers Awards, 2023
  • “Law Firm of the Year”, Peer2Peer Finance Awards, 2023



Solicitor, England and Wales


BA, English Literature, Durham University, 2012

GDL, University of Law, 2013

LPC, University of Law, 2014

A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.