FINAL NOTICE

To:
Ian Charles Hannam

Individual

Number:
ICH01012

ACTION

1.
For the reasons given in this notice, the Authority hereby imposes on

Mr Hannam a financial penalty of £450,000 for engaging in market

abuse.

REASONS FOR ACTION

2.
On 27 February 2012 the Authority gave Mr Hannam a Decision

Notice which notified him that pursuant to section 123(1) of the

Financial Services and Markets Act 2000 (“the Act”) the Authority had

decided to impose a financial penalty on him of £450,000 for two

instances of market abuse (improper disclosure) contrary to section

118(3) of the Act.

3.
On 26 March 2012 Mr Hannam referred this decision to the Upper

Tribunal (Tax and Chancery Chamber) (“the Tribunal”). The written

decision of the Tribunal was released on 27 May 2014 and can be

found on the Tribunal’s website at

nam-v-FCA.pdf.

4.
The Tribunal decided that Mr Hannam’s actions in sending two emails

on 9 September 2008 and 8 October 2008 constituted behaviour

falling within section 118(3) of the Act and that he was thereby

engaged in market abuse. His actions were not in the proper course

of his employment. He was not able to take advantage of the defence

provided in section 123(2) of the Act.

5.
In an order made by consent on 11 July 2014 the Tribunal

determined the reference by directing that the Authority should

impose on Mr Hannam a financial penalty of £450,000 pursuant to

section 123(1) of the Act.

PROCEDURAL MATTERS

6.
This Final Notice is given under, and in accordance with, section 390

of the Act.

Manner of and time for Payment

7.
The financial penalty must be paid in full by Mr Hannam to the

Authority by no later than 7 August 2014.

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If the financial penalty is not paid

8.
If all, or any, of the financial penalty is outstanding on 7 August

2014, the Authority may recover the outstanding amount as a debt

owed by Mr Hannam and due to the Authority.

9.
Sections 391(4), 391(6) and 391(7) of the Act apply to the

publication of information about the matter to which this notice

relates. Under those provisions, the Authority must publish such

information about the matter to which this notice relates as the

Authority considers appropriate. The information may be published in

such manner as the Authority considers appropriate. However, the

Authority may not publish information if such publication would, in

the opinion of the Authority, be unfair to Mr Hannam or prejudicial to

the interests of consumers or detrimental to the stability of the UK

financial system.

10. The Authority intends to publish such information about the matter to

which this Final Notice relates as it considers appropriate.

Authority contacts

11. For more information concerning this matter generally, contact Kevin

Thorpe (0207 066 4450) or Clare Hitchcock (0207 066 1490) at the

Enforcement and Financial Crime Division of the Authority.

Head of Department, Enforcement and Financial Crime Division,