Karen Butler


Karen Butler is a Partner in the firm’s European Financial Services Regulatory Practice.

Karen is highly experienced in advising on both UK and EU financial services regulation and providing practical and solutions focused advice to clients on a broad range of issues related to FS and Funds licensing, marketing, corporate governance (including the SMCR), custody, conduct, remuneration, prime brokerage services, trading and clearing, systems, controls and procedures, operational resilience, change in control notifications, cross border activities, benchmark administration regulation, Brexit restructuring, and regulatory divergence.

Karen has worked with her clients on a range of large-scale regulatory implementation projects on issues related to Brexit, MIFID II, EMIR, AIFMD and the UK IFPR and she assists clients in developing and updating policies, procedures, systems and controls to embed best practice and reflect regulatory expectations.

Karen regularly advises funds and fund managers on authorisation requirements under the UK AIFMR and the EU AIFMD and assists clients navigate their way through the fund marketing regimes in the UK and the EU (including under the passporting regime, pre-marketing notifications, NPPR notifications/ filings, and the UK financial promotion rules).

Karen brings notable experience in providing regulatory support to clients in relation to their capital markets, derivatives, and securitisation transactions.

Professional QualificationsSolicitor of the Senior Courts of England and Wales


  • Advising an international bank on establishing an agency securities lending business in the UK and Luxembourg. This included provides support on (a) regulatory perimeter issue, (b) structuring for Brexit, (c) compliance with CASS, (d) remuneration requirements, (e) tied agents, (f) corporate governance, (g) outsourcing, (h) developing compliance policies and procedures, and (i) liaising with regulators.*
  • Assisting various financial institution clients on Brexit restructuring projects.*
  • Advising clients on the UK Temporary Permissions Regime (TPR), obtaining authorisation upon existing the TPR.*
  • Advising investment firms and investment manager clients on how to operate on a cross border basis into the UK in reliance of an exclusion from the requirement to be authorised by the FCA (including firms who previously passported into the UK and who were previously in the UK TPR).*
  • Managing large multi-jurisdictional regulatory surveys for investment firm, corporate finance and alternative investment funds clients.*
  • Carrying out a wholesale review of a client’s CASS policies, procedures, and arrangements including the CASS resolution pack and assisting with remediation measures.*
  • Advising fund clients on marketing of funds under the pre-marketing, regime, the NPPR regime and SFDR disclosures including assisting with regulatory filings to UK and EU regulators, preparing practical do’s and don’ts guides and client checklists.*
  • Advising direct lending fund clients on cross border marketing rules and how to structure their direct lending in compliance with exemptions from the requirement to hold a banking license.*
  • Advising clients on implementation projects relating to MIFID II, EMIR and the UK IFPR.*
  • Assisting clients in drafting client documentation for prime brokerage services.*
  • Advising on the implementation of the FCA Consumer Duty regime.*
  • Advising clients on the application of the securitisation regulation in relation to financing of assets including trade receivables, commercial loans, shipping and transportation loans, mortgage and consumer loans.*
  • * Denotes experience from previous firm.
  • Birkbeck, University of London, MSc, Merit, 2012
  • BPP Law School, LPC, 2001
  • City, University of London, CPE, Law, 2000

    The University of Edinburgh, MA 2:1, 1999

    The University of Edinburgh, MA in Economic and Social History, 1999


  • Crypto-assets and initial coin offerings in Chapter 5 of Part 1 of Fintech: Law and Regulation (2nd Edition), Elgar Financial Law and Practice
  • Client briefings on issues such as AIFMD 2, UK IFPR implementation, UK and EU Securitisation Regulation, Operational resilience and outsourcing, Brexit, Remuneration code and SMCR


Karen has participated in various podcasts on UK regulatory matters including the UK IFPR.