The FCA has decided to fine Banque Havilland £10m; its former London branch CEO, Edmund Rowland, £352,000; David Weller, a former London branch senior manager, £54,000; and Vladimir Bolelyy, a former London branch employee, £14,200. The FCA has decided to ban all 3 individuals from working in financial services.
The FCA considers that between September and November 2017, Banque Havilland acted without integrity by creating and disseminating a document that contained manipulative trading strategies aimed at creating a false or misleading impression as to the market in, or the price of, Qatari bonds. The objective was to devalue the Qatari Riyal and break its peg to the US Dollar, thereby harming the economy of Qatar.
Banque Havilland intended to present the document to representatives of countries it considered might have reasons to want to put economic pressure on Qatar, including the United Arab Emirates, as a way of marketing its services.
The FCA has not found that the strategy in the document was implemented. However, such manipulative trading could have been a criminal offence, had it taken place in the UK.
The FCA found that Mr Edmund Rowland tasked Mr Bolelyy to draft the document and Mr Weller made a significant contribution to the content. Later, Mr. Edmund Rowland and Mr. Bolelyy disseminated the document, including by providing a copy to a representative of an Abu Dhabi sovereign wealth fund.
The FCA considers that Mr. Edmund Rowland, Mr. Weller, and Mr. Bolelyy failed to act with integrity and that they are not fit and proper persons to perform any function in relation to any regulated activities.
In the FCA’s view, the actions of Mr. Edmund Rowland and Mr. Weller are particularly serious, as both held positions of significant influence and were involved in the creation of the document.
Therese Chambers, Executive Director of Enforcement and Market Oversight at the FCA said 'Banque Havilland’s conduct actively encouraged the commission of financial crime, providing ideas for manipulative trading to someone it saw as having the political motivation to be potentially interested in such ideas. It barely needs stating, but such conduct is completely unacceptable. The misconduct of Mr. Edmund Rowland and Mr. Boleyy was deliberate. Mr Weller claimed to have believed that the other two were joking around but as a senior manager, he behaved recklessly. There was an obvious risk of impropriety and he willingly took that risk without seeking any assurances that things would go no further.'