AFB Seminar: The Prudential Regulation Authority’s Approach to Enforcement – Recent Policy Changes

AFB, in partnership with Simmons & Simmons, invites members to attend an in-person seminar on the approach and policy of the PRA’s Enforcement team.  

The session will cover PRA decision-making from an insider’s perspective, the role of PRA Supervision in the Enforcement process, and the PRA’s innovative approach to enforcement with the introduction of the Early Account Scheme. The seminar will be led by Tom Makin, who recently spent a year on secondment in the Bank of England’s Enforcement and Litigation Division. 

Why attend?

Forewarned is forearmed – the PRA’s approach to enforcement supports and supplements its regulatory and supervisory tools and PRA Supervision has a significant role in the PRA enforcement process, from referral to settlement. This session will offer insights into the PRA’s internal decision-making processes, its triggers for the commencement of enforcement investigations and tips for how firms can manage enforcement risk both before and during enforcement.

Who should attend?

This session is aimed at Compliance and Legal teams of AFB member banks.

Speakers

Caroline Hunter-Yeats, Partner, Disputes and Investigations

Caroline is the key Contentious Regulatory specialist in the market for the FCA’s Consumer Duty, having co-led Simmons’ implementation work with over 150 clients, as well as now advising firms who are subject to firm FCA supervisory engagement.   She is a specialist in large-scale investigations but also gets instructed to defend individuals facing regulatory investigations. Caroline is well known for her gravitas with senior individuals, tact in sensitive investigations, forthright analysis and straight talking when needed. 

Caroline’s specialisms cover FCA and PSR enforcement investigations, contentious regulatory aspects of governance, conduct risk and financial crime and risk management across a wide range of issues.

Thomas Makin, Managing Associate, Disputes and Investigations

Tom is a contentious regulatory specialist in the Disputes & Investigations group in London. He advises major clients – from US investment banks to digital asset firms and individuals – on high-stakes matters, drawing on experience from secondments at a leading UK bank and a US investment bank’s Conduct Risk team.

He also completed a 12-month secondment with the PRA’s Enforcement and Litigation Division, including work on the MS Amlin Final Notice, giving him unique insight into PRA supervision and enforcement. Tom is known for his commercially focused approach, deep regulatory understanding, and expertise in complex risk reviews, structured products, and new regulations like Consumer Duty.

Lily Mortimer, Supervising Associate, Disputes and Investigations

Lily is a Supervising Associate in the Disputes & Investigations group in London, specialising in complex commercial disputes and advising financial institutions. Her recent experience with banking clients includes advising on a $800m dishonest assistance claim, a potential contract dispute, and other high-value cross-border disputes. She recently completed a six-month secondment to a major global financial institution.

Lily has also acted on a range of aircraft leasing disputes, including a successful Commercial Court trial. She also has experience of acting on disputes in the TMT and ENRI sectors and advising on contentious regulatory investigations. Lily trained and qualified at Simmons & Simmons, including a trainee secondment to the firm’s Financial Markets team in Paris. She also won a WeAreTheCity Rising Star award in 2023 arising out of her involvement in the firm’s gender balance initiatives.

Logistics

Fee:           Included in AFB membership

Location:    Simmons & Simmons, CityPoint, 1 Ropemaker St, London EC2Y 9SS

Date:          Tuesday 24 June 2025

Time:          09:00 – 10:15 (arrivals & breakfast from 08:30)

If you would like to submit a question that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk You will receive details on how to join this session a week before the event.