Experience
Aaron specialises in advising on four core areas:
- FCA regulatory advice to the wealth management sector including personal pension providers (e.g. SIPP operators)
- Systemic loss, root-cause analysis and remediation projects, including mass complaint scenarios
- Avoiding, managing and defending FCA supervisory interventions, including s.166 skilled person reviews, VREQ requests and FCA own-initiative powers
- Defending firms and individuals under FCA enforcement investigations
Aaron advises the retail wealth management sector across all FCA requirements, with a particular focus on the practical application of the rules to business models, governance and client outcomes. He regularly advises on contractual and regulatory issues arising from distribution and intermediated arrangements, including relationships between advisers, DFMs, platforms and custodians. His work also spans advice propositions and suitability, Consumer Duty implementation, conduct risk management, CASS and safeguarding issues, supervisory interventions and enforcement risk.
Having spent two years as in-house regulatory counsel at Raymond James and undertaken a secondment at Hargreaves Lansdown, Aaron brings a detailed and practical understanding of the wealth management sector that is rare to find among lawyers. He is a key part of the team appointed to the FCA’s section 166 Skilled Persons panel.
Aaron also helps any FCA authorised firm or individual with FCA supervisory intervention and/or enforcement investigations.
Representative work experience.
Advisory support:
- Advising a large wealth manager on how to navigate inducements, conflicts of interest and tax considerations as part of an unusual acquisition arrangement
- Assisting on multiple FCA authorisation and variation of permission applications including a European custodian opening UK brokerage and custody services and two international broker-custodians’ seeking personal pension (SIPP) permissions
- Drafting and advising on a wholesale rewrite of a large wealth manager’s advisory and DFM client agreements and providing a full suite of agreements for an adviser, DFM and platform provider including the associated distribution agreements
Assisting investment firms with winding down their custody businesses:
- Voluntary wind-down of custody businesses and transition to Model B arrangements
- Administrations (Hartley Pensions and Greyfriars) and Special Administrations, including Dolfin Financial (UK), IBP Markets and Hartmann Capital
- Advising SIPP operators on regulatory considerations for setting up a treasury function to manage SIPP cash held by a bare trustee (i.e. outside of CASS) and associated Consumer Duty obligations including fair value assessments
FCA Supervisory intervention, systemic liability and remediation projects:
- Advising multiple investment advice firms on the FCA’s 2024 ongoing advice services thematic review, including providing detailed advice on regulatory requirements; advising on strategy to manage regulatory risk (including successfully preventing the instruction of a skilled person for two firms); and helping to devise remediation projects
- Assisting a firm in responding to a VREQ request, designing and delivering a client contact exercise, and securing removal of the requirement within four months
- Supporting a financial advice firm with an internal investigation into two financial advisers who had received significant ‘introducer’ payments relating to undisclosed investment transactions
- Devising a complaint handling process for a large investment firm to manage thousands of complaints arising from a single matter. This included: identifying and creating different complaint tracks; providing an outsourced triage service; creating a complaint response playbook; and advising the complaint working group on escalations as required
- Assisting multiple firms with multiple and potentially systemic FOS complaint scenarios
FCA investigations and enforcement:
- Representing a CEO of a UK PLC accused of making misleading statements to the stock market under section 89 of the Financial Markets Act 2012
Obtaining discontinuance of various FCA enforcement investigations including:
- A CEO and connected companies in a dual-track FCA investigation relating to the creation, FinProm approval and promotion of minibonds
- A CEO and wealth management firm that was investigated for its role in providing section 21 approval to minibond providers
- A wealth management firm investigated for alleged investment due diligence and liquidity monitoring; misleading communications to clients; and failure to have controlling client money (CASS) permissions
Testimonials
“I had the pleasure of working with Aaron Osborn and cannot recommend him highly enough. Throughout our case, he demonstrated incredible tenacity and an unwavering commitment to detail. His approach was rigorous and thorough, yet always delivered with a calm, positive demeanour, making a stressful situation feel far more manageable. I felt confident and supported every step of the way.” (Legal 500)
Recent Articles / Press Releases:
- 27 April: What does the Supreme Court decision in Kession mean for Principals and ARs? | DWF Group
- 1 April 2026: DWF and Hailsham Chambers team secure Supreme Court victory for Kession Capital Limited | DWF Group
- 16 March 2026: Wealth Management Annual Review of 2025 | DWF