Gillian Roche-Saunders

Partner & Head of Bates Wells Compliance


I advise financial services firms on the regulatory issues affecting them. I run our financial services regulatory consultancy, Bates Wells Compliance.

My compliance experience spans a wide range of financial sectors. My area of particular specialism is regulation for the venture finance industry – companies involved in providing finance to SMEs. My clients in this part of the market range from venture capital and private equity investment houses to corporate finance advisers and business angels. I am particularly well known in the EIS, crowdfunding and P2P lending industries for being the go-to consultant for regulatory support.

The advice I provide covers all areas of regulation that affect UK financial services companies including the FCA rules and regulation from Europe such as AIFMD, MiFID and PSD. My advice is both technical and practical, and I take particular pride in making sure my recommendations are closely tailored to the needs of each client.

I especially enjoy advising firms on their regulatory strategy for significant changes to their business such as the structuring of new products and services, the need for new regulatory permissions and complex changes in ownership structure.

More widely, I have supported clients in a range of sectors from wealth management, social impact investing, banking, e-money and payment services, custodians, consumer credit, property funds and hedge funds.

  • Providing a holistic regulatory healthchecks on a crowdfunding platform involving desk-based assessment and FCA-style interviewing of key individuals.
  • Preparing firms for MIFID II compliance including a gap analysis, new policies and procedures, implementation workshops and training courses.
  • Identifying 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.
  • Advising firms on potential impact of SM&CR.
  • Delivering interactive training of financial promotions rules to marketing, sales legal and compliance professionals.
  • Reviewing boundary between the concept of bulletin boards and MTFs/ OTFs under MIFID II.
  • Advising 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.
  • Undertaking review of advice giving process, including KYC information gathering, suitability assessments and preparing firm for MIFID II suitability updates.
  • Facilitating financial crime risk assessment covering AML, sanctions CTF, bribery, data security and fraud.
  • Training the compliance officer and money laundering reporting officer for a newly authorised firm.
  • Advising a firm in relation to sensitive suspicious activity reports.
  • Identifying the appropriate activities for a payment services provider and guiding them on FCA authorisation.
  • Preparing asset manager to change status from small authorised AIFM to full scope AIFM.
  • Reviewing user journey/ wire frame for an online platform to ensure compliance with AML, financial promotions, appropriateness and TCF considerations.
  • Integrated compliance review for a robo adviser's online marketing campaign.
  • Supporting a wealth manager with significant complaints handling project including liaising with the FOS.
  • Obtaining FCA authorisation for a microfinance business.
  • Advising a private bank on the compliance risks of alternative assets.
  • Creating compliance framework for online transaction platform.
  • Regulatory due diligence for a PE firm seeking to acquire a FinTech company.
  • Designing appropriateness tests and compliant user journeys for an ecommerce business.
  • Reviewing financial promotion of retail-focussed alternative investment fund.
  • Devising a policy for social media compliance for an asset manager.
  • Advising a product provider on their design and distribution governance.
  • Performing a complete health check for a fund manager.
  • Advising a foreign crowdfunding platform on regulatory strategy for setting up in the UK.
  • Preparing a variation of permission for a firm seeking client money permission.
  • S166 review of a financial promoter.
  • Representing 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)