The UK Financial Conduct Authority (FCA) has decided to fine Banque Havilland £10 million.

The regulator also fined the company’s 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 three 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 which 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 regulator 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.

Banque Havilland, Edmund Rowland and Vladimir Bolelyy have referred their Decision Notices to the Upper Tribunal where they will each present their case. David Weller has not referred his Decision Notice to the Upper Tribunal. David Rowland, who has been given third party rights, has also referred all 4 Decision Notices to the Upper Tribunal and will present his case.