Gillian Roche-Saunders

Partner at Bates Wells & Head of Bates Wells Compliance


I am an advisor to the financial services industry, guiding firms on the regulatory issues affecting them. Although I have supported a wide range of financial businesses over the years, I focus particularly on those in the venture capital, private equity, fintech and social impact sectors. I founded and run our consultancy dedicated to this work, Bates Wells Compliance.

The advice and support I provide spans European regulations like AIFMD, MiFID II, PSD2 and PRIIPs, through to UK-specific regimes like SM&CR, the client money regime and the rules for consumer credit firms.  The work we do ranges from giving highly technical advice on what is and is not regulated, through to providing training on hot topics such as the financial promotions rules and even rolling up our sleeves and going in to help firms with their daily compliance tasks.

I am known for giving advice that is not only technically excellent but really bears in mind what my client is looking to achieve and the constraints they are working within.  Its perhaps no surprise then that I spend a lot of my time working closely with firms on their strategic planning as there are scaling their businesses and going through changes.  This kind of strategic regulatory work includes, for example, the launch of new products, changes in a firm’s structure and the acquisition of new regulatory permissions. 

  • I provide holistic regulatory health-checks on a crowdfunding platform involving desk-based assessment and FCA-style interviewing of key individuals.
  • I prepare firms for MIFID II compliance including a gap analysis, new policies and procedures, implementation workshops and training courses.
  • I identify the best investment structure to raise SME finance given regulatory requirements and drafting compliance documentation to support the launch of a bond and equity product.
  • I advise firms on potential impact of SM&CR.
  • I deliver interactive training of financial promotions rules to marketing, sales legal and compliance professionals.
  • I work on reviewing the boundary between the concept of bulletin boards and MTFs/ OTFs under MIFID II.
  • I advised on establishment of a new P2P lending platform structure, liaising with FCA re structure of the platform and deals, and securing FCA authorisation for the firm.
  • I undertook a review of advice giving process, including KYC information gathering, suitability assessments and preparing firm for MIFID II suitability updates.
  • I facilitated a financial crime risk assessment covering AML, sanctions CTF, bribery, data security and fraud.
  • I have trained the compliance officer and money laundering reporting officer for a newly authorised firm.
  • I advised a firm in relation to sensitive suspicious activity reports.
  • I have identified the appropriate activities for a payment services provider and guiding them on FCA authorisation.
  • I prepared the asset manager to change status from small authorised AIFM to full scope AIFM.
  • I reviewed user journey/ wire frame for an online platform to ensure compliance with AML, financial promotions, appropriateness and TCF considerations.
  • I carried out an integrated compliance review for a robo adviser's online marketing campaign.
  • I supported a wealth manager with significant complaints handling project including liaising with the FOS.
  • I obtained FCA authorisation for a microfinance business.
  • I advised a private bank on the compliance risks of alternative assets.
  • I created compliance framework for online transaction platform.
  • I carried out regulatory due diligence for a PE firm seeking to acquire a FinTech company.
  • I have designed appropriateness tests and compliant user journeys for an ecommerce business.
  • I reviewed the financial promotion of retail-focussed alternative investment fund.
  • I devised a policy for social media compliance for an asset manager.
  • I advised a product provider on their design and distribution governance.
  • I performed a complete health check for a fund manager.
  • I advised a foreign crowd-funding platform on regulatory strategy for setting up in the UK.
  • I prepared a variation of permission for a firm seeking client money permission.
  • I carried out a S166 review of a financial promoter.
  • I represented a wealth manager to the Financial Ombudsman Service.

Qualifications and career

  • Head of Bates Wells Compliance, 2016
  • Principal and Head of Venture Finance at Bovill, 2014
  • CISI Investment Compliance Diploma 2012
  • Regulatory Consultant at Bovill, 2011
  • Investigations Adjudicator at The Law Society of England and Wales, 2009
  • Birkbeck, University of London, MSC in Conflict Resolution, 2011
  • Technical Adviser at The Law Society of England and Wales, 2008
  • Team Coach and Adviser at The Law Society of England and Wales, 2006
  • Investigator at The Law Society of England and Wales, 2004
  • University of Leicester, LLB Law with French Law and Language, 2004
  • Université de Jean Moulin, Lyon III, DEUF diploma in French Law, 2003

Pro bono, memberships, and appointments

  • Regulatory advisor to UK Crowdfunding Association
  • Board Member at EIS Association
  • Chair of Regulatory Committee for EIS Association
  • Member of Chartered Institute for Securities and Investment (MSCI)
  • Start-up Advice Supervisor at Queen Mary University’s QLegal programme (2015-2016)
  • Member of Technical Committee at UK Business Angels Association (2013-2016)
  • Community Mediator, CALM Mediation (2010-2015)
  • Panel Member, Wandsworth Youth Offending Team (2006 –2008)
  • Committee Member of BVCA Venture Capital Committee
  • Business Coaching Specialist, Finance Innovation Lab
  • Faculty Member, Allia’s Serious Impact Incubator