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Samantha Paul


Samantha Paul
  1. People

Samantha Paul

Samantha Paul

Knowledge & Innovation Counsel


London

Samantha Paul
  1. People

Samantha Paul

Samantha Paul

Knowledge & Innovation Counsel


London

Samantha Paul

Knowledge & Innovation Counsel

London

T: +44 (0) 20 3400 3194

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  • Biography

Biography

Samantha is a skilled lawyer with extensive private practice and in-house experience of handling complex, multi-jurisdictional regulatory and criminal investigations, English and overseas litigation, and related advisory work.

Samantha brings this experience to her role as BCLP’s Principal Knowledge & Innovation Counsel for the Financial Services Disputes and Investigations Practice Group and the White Collar team. Her role includes providing legal knowledge, training and thought leadership, as well as promoting particular capabilities to existing and potential clients. She also assists the teams with strategy, development and innovation initiatives.

Before joining BCLP, Samantha worked for a number of years in the Financial Services Litigation team at another international law firm, where her experience included acting on a long-running multi-jurisdictional investigation in relation to LIBOR for a well-known bank.

Samantha then moved in-house, serving as Senior Counsel in the Litigation and Regulatory Enforcement team at an international investment bank.  Her in-house experience includes taking a lead role in the handling of investigations into allegations of misconduct relating to foreign exchange benchmarks, transaction monitoring in connection with sanctions, and suspicious transactions raising anti-money laundering concerns.

She has experience across the full lifecycle of regulatory and criminal investigations by multiple regulators and prosecutors, from initial discharge of investigations through to outcome and full remediation.  She also has experience handling follow-on and related employment and civil litigation in various jurisdictions. 

Emerging Themes in Financial Regulation & Disputes

We anticipate a pivotal year for investigations and enforcement

Our 2026 forecastIcon: arrow

Related Capabilities

Financial Services Corporate & Regulatory Team Financial Services Corporate & Regulatory Team

Financial Regulation Compliance & Investigations Financial Regulation Compliance & Investigations

  • Financial Services Corporate & Regulatory Team

  • Financial Regulation Compliance & Investigations

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Cyber Litigation in Financial Services: managing the evolving risk

Cyber incidents are increasingly giving rise to complex, long‑tail litigation risk, particularly for financial services firms. As regulators place growing emphasis on operational resilience, outsourcing governance and accountability, the same regulatory findings may be repurposed to support civil follow‑on claims long after incidents occur. Regulatory investigations are taking longer to conclude and, alongside damages claims, courts are showing an increased willingness to grant urgent injunctive relief to prevent data misuse. As a result, firms should approach cyber preparedness not only as a regulatory or operational issue, but as a litigation risk mitigation exercise – aligning regulatory engagement, disclosure decisions and contractual liability planning from the outset. This article is the second in our three‑part Emerging Themes in Financial Regulation & Disputes 2026 series and follows our earlier analysis of cyber resilience and the 2026 regulatory shift. It examines the evolving litigation and regulatory landscape shaping cyber and operational resilience expectations for the year ahead and identifies practical priorities for financial services firms seeking to respond proactively. Our accompanying articles consider (i) cyber resilience and the 2026 regulatory shift; and (ii) operational resilience and the growing influence of critical third‑party designations.
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Jun 02, 2026

FCA Shares Joint Vision on Tokenisation for UK Wholesale Markets

Technological innovation continues to reshape traditional financial systems and infrastructure, but the regulatory response is now entering a more decisive phase. As explored in our Emerging Themes in Financial Regulation and Disputes 2026 articles to date, the focus is shifting from exploration to implementation across digital assets and market infrastructure. Against this backdrop, the FCA and Bank of England (BoE) have published a joint call for input on the introduction of tokenisation in UK wholesale financial markets. Responses to the call for input close on 3 July 2026. This article explores the key elements of that proposal and what it means for firms.
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The UK’s financial services reform programme has reached a decisive inflection point, with the publication of the Financial Services & Markets Bill 2026 and the May 2026 Regulatory Initiatives Grid marking a clear shift from policy development to implementation and execution. As a mid‑year update to our Emerging Themes in Financial Regulation & Disputes 2026 outlook, these developments confirm – and refine – the trajectory identified at the start of the year: a move towards a more flexible, growth‑oriented and regulator‑led framework, driven by the interplay of politics, people and technology. This should not be understood as deregulation. Rather, the direction of travel is one of recalibration, with reduced legislative prescription offset by increased supervisory discretion, a broader regulatory perimeter and heightened expectations of accountability – particularly in relation to senior individuals, consumer outcomes and technology‑driven risks. The latest reforms also signal a decisive transition from consultation to delivery, with clearer timelines, more proactive supervisory engagement and a growing emphasis on outcomes‑based regulation. For firms, the message is clear: 2026 is already shaping up to be a busy and consequential year. The pace of change is accelerating, and the regulatory environment is becoming more dynamic, judgement‑based and interventionist, requiring a strategic approach to managing both regulatory risk and opportunity.
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As crypto moves from the margins to the mainstream of the UK financial system, regulatory uncertainty is giving way to structured supervision, authorisation and enforcement. BCLP’s Emerging Themes 2026 crypto series tracks this transition in real time — from the expansion of the regulatory perimeter, through new conduct and market integrity regimes, to the operational and governance expectations that will define participation in regulated crypto markets. This article focuses on the latest step in that progression: the FCA’s publication of its perimeter guidance in Consultation Paper CP26/13, a critical development in translating legislative intent into practical compliance obligations as the UK’s new crypto regime takes shape.
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UK regulators have not yet fully exercised the breadth of their powers to address shortcomings in organisational cyber‑security measures—but that restraint is unlikely to continue. The policy statements published on 18 March 2026 by the FCA, PRA and Bank of England, introducing a new single regime for operational incident and third‑party reporting, signal the direction of travel. The framework—under which firms must report serious cyber and operational incidents through a unified portal and provide structured information on their critical third party (CTP) dependencies—reflects the UK regulators’ sharpened focus on digital risk, system resilience, and their recognition of the vulnerabilities inherent in  complex technological supply chains. This shift sits alongside the UK government’s broader agenda. As the Cyber Security and Resilience (Network and Information Systems) Bill (NIS Bill) progresses and HM Treasury (HMT) prepares to designate major technology providers as CTPs using its FSMA powers, firms can expect a step‑change in supervisory expectations. Cyber‑security, data protection and operational resilience disciplines must now operate as a single, evidence‑based ecosystem capable of withstanding assertive regulatory challenge. The coming year will require firms not only to demonstrate alignment on paper, but to evidence—consistently and credibly—that controls work in practice. This article is the first in our three part Emerging Themes in Financial Regulation & Disputes 2026 series. We examine the evolving regulatory and risk landscape shaping cyber and operational resilience expectations for the year ahead—and set out practical priorities for financial services firms seeking to respond proactively. Our accompanying articles will examine (i) the evolving cyber litigation risks facing financial services firms and (ii) operational resilience and the growing influence of CTP designations.
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Insights
Jun 04, 2026
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Insights
Jun 02, 2026
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Technological innovation continues to reshape traditional financial systems and infrastructure, but the regulatory response is now entering a more decisive phase. As explored in our Emerging Themes in Financial Regulation and Disputes 2026 articles to date, the focus is shifting from exploration to implementation across digital assets and market infrastructure. Against this backdrop, the FCA and Bank of England (BoE) have published a joint call for input on the introduction of tokenisation in UK wholesale financial markets. Responses to the call for input close on 3 July 2026. This article explores the key elements of that proposal and what it means for firms.
Insights
May 27, 2026
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Insights
May 01, 2026
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Insights
Apr 21, 2026
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As crypto moves from the margins to the mainstream of the UK financial system, regulatory uncertainty is giving way to structured supervision, authorisation and enforcement. BCLP’s Emerging Themes 2026 crypto series tracks this transition in real time — from the expansion of the regulatory perimeter, through new conduct and market integrity regimes, to the operational and governance expectations that will define participation in regulated crypto markets. This article focuses on the latest step in that progression: the FCA’s publication of its perimeter guidance in Consultation Paper CP26/13, a critical development in translating legislative intent into practical compliance obligations as the UK’s new crypto regime takes shape.
Insights
Apr 07, 2026
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UK regulators have not yet fully exercised the breadth of their powers to address shortcomings in organisational cyber‑security measures—but that restraint is unlikely to continue. The policy statements published on 18 March 2026 by the FCA, PRA and Bank of England, introducing a new single regime for operational incident and third‑party reporting, signal the direction of travel. The framework—under which firms must report serious cyber and operational incidents through a unified portal and provide structured information on their critical third party (CTP) dependencies—reflects the UK regulators’ sharpened focus on digital risk, system resilience, and their recognition of the vulnerabilities inherent in  complex technological supply chains. This shift sits alongside the UK government’s broader agenda. As the Cyber Security and Resilience (Network and Information Systems) Bill (NIS Bill) progresses and HM Treasury (HMT) prepares to designate major technology providers as CTPs using its FSMA powers, firms can expect a step‑change in supervisory expectations. Cyber‑security, data protection and operational resilience disciplines must now operate as a single, evidence‑based ecosystem capable of withstanding assertive regulatory challenge. The coming year will require firms not only to demonstrate alignment on paper, but to evidence—consistently and credibly—that controls work in practice. This article is the first in our three part Emerging Themes in Financial Regulation & Disputes 2026 series. We examine the evolving regulatory and risk landscape shaping cyber and operational resilience expectations for the year ahead—and set out practical priorities for financial services firms seeking to respond proactively. Our accompanying articles will examine (i) the evolving cyber litigation risks facing financial services firms and (ii) operational resilience and the growing influence of CTP designations.
Insights
Feb 11, 2026
FCA publishes further information on its approach to the UK’s new cryptoasset regime
Insights
Feb 05, 2026
FCA Enforcement Watch and Beyond – Five Headline Trends for 2026
Insights
Jan 27, 2026
Rebalancing risk to unlock growth: How financial services regulation will shape the economy in 2026

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