Warning Notice

On , the Financial Conduct Authority issued a Warning Notice to the Company

Warning notice statement 14/12

The Financial Conduct Authority (the FCA) gave an individual a warning notice on 18
June 2014 proposing to take action in respect of the conduct summarised in this
statement.

IMPORTANT: a warning notice is not the final decision of the FCA. The
individual has the right to make representations to the Regulatory Decisions
Committee (RDC) which, in the light of those representations, will decide on
the appropriate action and whether to issue a decision notice. The RDC is a
Committee of the FCA board which decides whether the FCA should give certain
statutory notices described as within its scope by the FCA’s Handbook.

If a decision notice is issued, the individual has the right to refer the matter to
the Upper Tribunal which would reach an independent decision on the
appropriate action for the FCA to take, if any.

If either the RDC or the Upper Tribunal decide that no further action should be
taken, the FCA will publish a notice of discontinuance provided it has the
individual’s consent.

The following is a summary of the reasons why the FCA gave the individual a warning
notice:


The FCA considers that, over a period of more than three and a half years the
individual, who was employed at a bank, was knowingly concerned in the
contravention of Principle 5 by the bank for significant failings in relation to an
interest rate benchmark.



In particular, the FCA considers that the individual:

o
Made requests to the bank’s interest rate benchmark submitters, in an attempt to
influence their interest rate benchmark submissions;


o
Made interest rate benchmark submissions which took into account requests
made by traders to benefit their positions;


o
Took into account the interest rate derivative positions on the trading book for
which the individual was responsible when making interest rate benchmark
submissions; and


o
Colluded with an interdealer broker in an attempt to influence the interest rate
benchmark submissions of other banks, and in return for their assistance,
facilitated corrupt brokerage payments.


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