Warning Notice

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

Warning notice statement 14/3

The Financial Conduct Authority (the FCA) gave an individual a warning notice on 21
January 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 nearly two 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 Took into account the positions on the trading book for which the individual was
responsible when making interest rate benchmark submissions,

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

o
Colluded with a trader at another bank, by making interest rate benchmark
submissions which took into account requests made by him.






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