Sarah Wheeler

Sarah is a Director at Marfire and a resident of the Cayman Islands, where she provides independent directorship services to foundation companies, funds, and operating companies with a Web3 strategy.

Sarah practised as a lawyer for 12 years at A&O Shearman, Wilmer Hale and Barclays Bank PLC before joining the U.K. regulator, the Financial Conduct Authority (FCA), then more recently, the Cayman Islands Monetary Authority (CIMA).

At the FCA, Sarah worked closely with overseas regulators and U.K. Government stakeholders to implement several new financial crime initiatives including a new ‘supervisor of supervisors’, an intelligence network for ‘professional enablers’ and the Financial Action Task Force (‘FATF’)’s rules for virtual asset service providers (VASPs). She also co-chaired the FATF’s Risk-Based Guidance for Lawyers, Accountants and TCSPs.

More recently, as Head of the AML Division at CIMA, Sarah led the implementation of the VASP supervisory regime in the Cayman Islands. She spear headed the first AML/CFT risk assessment of VASPs and virtual assets, established a methodology for identifying unregulated entities and collecting Travel Rule information, and drafted the framework for assessing and approving registration applications. Additionally, she was responsible for conducting the first onsite inspections of VASPs and taking enforcement actions for non-registration.

Sarah played a pivotal role in advocating for the Cayman Islands' removal from the FATF’s grey list and acted as a FATF Financial Assessor for the Mutual Evaluation of St. Vincent and the Grenadines. Passionate about excellence and innovation and the Web3 space, she believes Cayman is an ideal location for top-tier blockchain-driven businesses and DAOs. She is the Chair of the Blockchain Association of Cayman Islands’ Regulation and Education Committee.

Admitted as an Attorney in (but not practising):

o   Supreme Court of England and Wales (2004)

o   Higher Rights of Audience, England and Wales (2006)

Professional Qualifications:

o   Master of Arts in History(First Class), University of Edinburgh (UK)

o   Post Graduate Diploma in Law, Nottingham Law School(UK)

o   Legal Practice Course, Nottingham Law School(UK)