Sarah Hitchins


Sarah specialises in advising clients on regulatory and internal investigations involving the most high-profile and sensitive issues, which typically attract the highest levels of scrutiny from regulators, the media and politicians.

She has significant experience of advising on and conducting UK and cross-border investigations involving a broad range of issues, including market abuse, insider trading, financial crime (civil and criminal), cyber and data security breaches, individual accountability, operational resilience, fund liquidity issues, misselling, environmental disclosures and ‘greenwashing’, systems and controls failures, whistleblowing, cultural issues and non-financial misconduct (including, in particular, allegations of bullying, harassment, discrimination and sexual misconduct).

Sarah has a notable focus on representing clients that are involved in regulatory investigations, including in particular investigations conducted by the UK Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA), where she previously completed a secondment in its Enforcement Division. Sarah has also represented a number of clients in investigations concerning compliance with UK Listing and Takeover Code requirements.

Alongside her investigations practice, Sarah has advised over 200 clients in relation to the UK Senior Managers and Certification Regime (SMCR). Her advice spans issues relating to both the implementation and post-implementation operation of the SMCR, in addition to assisting candidates with preparations for their Senior Manager authorisations interviews with the FCA and the PRA. Sarah is specifically sought out by clients to advise them on investigations with significant individual accountability considerations, including assessments of fitness and propriety, potential breaches of the FCA and PRA Codes of Conduct and potential adjustments to individuals’ deferred remuneration, due to her expertise in these areas.

Sarah has been selected by Global Investigations Review (GIR) as one of the top 100 women in investigations, and she has also been recognised by LegalWeek/ as one of the UK’s “Rising Star” female lawyers in recognition of her leading financial services contentious regulatory expertise and experience.

Published Work

  • Regular contributor to Practical Law Company’s contentious regulatory materials.
  • Editor of Investigations Insight blog, which focuses on the latest trends, risks and developments in financial services investigations.



Admitted as a solicitor, England and Wales, 2011


BA and MA, Law, University of Cambridge (Gonville & Caius College), 2008

LPC, BPP Law School (London), 2009

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.