Introduction

The Financial Conduct Authority fined several banks for their misconduct in the FX market. On the back of the fines and findings from the investigations, the FCA launched an FX market wide remediation programme. Through the remediation programme, the FCA asked a number of firms to perform self-assessments against specific FX-related risks and provide attestations to the FCA.

FCA FX specified risk

Through their market wide remediation programme the FCA identified a number of risks and behaviours that contributed to miscondut:

• attempting to manipulate or control fixes

• misleading clients by implying they are getting the best rate, when in fact the rate they received may have included a significant 'hard mark-up'

• engaging in coordinated trading to gain an unfair advantage

• performing partial fills of client orders but not passing to the client the correct fill

• using layering or wash trades

• deliberately triggering client stop loss orders

• front running

• sharing confidential information with clients and traders at other firms

• unfairly assigning clients the worst rate available in relation to 'transaction window' trading

• inappropriately using personal dealing accounts, including spread betting

FCA FX fines

Firm	Fine (million USD)	Date
Barclays	446	20 May 2015
Citibank	358	12 Nov 2014
HSBC	343	12 Nov 2014
JPMorgan	352	12 Nov 2014
RBS	344	12 Nov 2014
UBS	371	12 Nov 2014
Total	2,214