Having been a partner since 2008, Rachel lives and breathes financial services, specialising in regulatory investigations and banking and financial markets litigation.

Rachel has acted for and advised various financial institutions and corporate entities, including banks, brokers, asset managers, custodians, trading platforms, SIPP operators, fintech companies and payment services providers, as well as individuals within those organisations, in a wide range of complex matters. Rachel has also been appointed as a Skilled Person pursuant to s166 FSMA 2000. Her expertise in the sphere of regulatory issues has led her to advise in connection with matters involving numerous regulatory bodies, including the Financial Conduct Authority, the Payment Services Regulator, the Financial Ombudsman Service, the Financial Services Compensation Scheme, the Insolvency Service of the Department for Business, Innovation and Skills and the National Crime Agency to name but a few.

"Rachel Couter is technically strong and strategically impressive. She is an exceptionally skilful lawyer, with a real eye for detail and a comprehensive knowledge of banking and financial services law" - Legal 500 (Contentious FS regulatory, Band 4).

Helping you succeed in tomorrow's world

Heading up our contentious financial services practice, I have a wealth of knowledge of how the regulators think and how regulatory issues can interact with commercial financial services disputes. Favourite topics include market abuse / insider dealing, mis-selling, suitability / appropriateness, AML, market manipulation, systems and controls, treating customers fairly, safeguarding, responsible lending and transaction reporting.

I am known for being technically strong, with a calm relaxed style and an ability to cut through the detail and give straight talking and strategic advice.


S166 Skilled Person

Acting as s166 skilled person in relation to the review of misselling of financial products by a bank and consequential losses suffered by customers.

Market abuse / insider dealing

Representing individuals within a merchant bank in relation to allegations of insider dealing.


Acting as the s166 FSMA 2000 Skilled Person overseeing HSBC's past business review of its sales of interest rate hedging products.


Advised the Board of directors of the UK entity, following the discovery of a massive fraud in its German parent, including dealing with the suspension of Wirecard UK's payments licence and the subsequent wind-down of the business.

Business Banking Resolution Service

Advised a number of SME Representatives in respect of the set up of the Business Banking Resolution Service, the voluntary extension of the Financial Ombudsman Service for complaints against 7 of the largest banks.

Comet plc

Representing the board of Comet plc following its collapse.