Aaron Osborn
Aaron has broad experience across the Financial Services sector, acting on compliance, advisory and contentious Investigations.
Having spent two years working as the in house regulatory lawyer for Raymond James, the UK subsidiary of a Fortune 500 US wealth manager, Aaron has a detailed understanding of the wealth management sector and now represents UK wealth managers, advising on compliance, new business propositions, distribution and conduct risk.
Aaron acts in matters involving systemic risk, multiple claims and (FOS) complaints as well as defending individuals and firms in enforcement action (civil and criminal) brought by the FCA (and other regulators).
Practice Area
Panel
- Contributing Author
Qualified Year
- 2016
Experience
- RPC (trainee) (2014 - 2016)
- Raymond James Investment Services Limited (Legal and Compliance Officer) (2016 - 2018)
- DWF (2018 - Present)
Qualifications
- LPC (2013 to 2014)
- Law LLB (2010 to 2013)
Education
- BPP (2013 to 2014)
- Queen Mary University of London (2010 to 2013)
1 Contributions by Aaron Osborn
PRACTICE NOTES
FCA Consumer Duty: complaints handling, RCA and data, board oversight, foreseeable harm and FOS redress expectations
In March 2026, the FCA published FG26/2: Good and Poor Practice on identifying harm.
FG26/2 sits alongside broader regulatory changes aimed at modernising redress and complements the Consumer Duty material in FG22/5 Final non-Handbook Guidance. This Practice Note is currently in the process of being revised to take full account of this development. See: HMT and FCA outline planned reforms of the FOS. The Financial Conduct Authority’s (FCA) Consumer Duty (the Duty) applied from 31 July 2023 for open products, and from 31 July 2024 for closed products, establishing heightened protections by obliging firms to act to secure good outcomes for retail clients. The Duty is anticipatory, requiring firms to embed customers at the centre of their operations, and to provide products and services that are suitable and offer fair value. This also entails the ongoing tracking, careful evaluating, and prompt addressing of claims and complaints. This Practice Note explores what the Duty means for firms’ complaint handling strategies, with particular emphasis on the FCA’s observations following its 2024 Consumer Duty thematic review covering complaints and root cause analysis. For detail on the core components of the Duty, see Practice Note: The FCA Consumer Duty—essentials. For key developments relating to...
Financial Services
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