The Financial Conduct Authority (FCA) said in a decision notice on 5 May it had decided to fine Banque Havilland £10m, its 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 further decided to ban all three individuals from working in financial services.

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 four Decision Notices to the Upper Tribunal and will present his case. 

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 FCA found that Edmund Rowland tasked Bolelyy to draft the document and Mr Weller made a significant contribution to the content. Later, Edmund Rowland and Bolelyy disseminated the document, including by providing a copy to a representative of an Abu Dhabi sovereign wealth fund.

The FCA considers that Edmund Rowland, Weller and 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 Edmund Rowland and Weller are particularly serious, as both held positions of significant influence and were involved in the creation of the document.

Therese Chambers, executive director of enforcement and market oversight at the FCA, said: "Banque Havilland's conduct actively encouraged the commission of financial crime, providing ideas for manipulative trading to someone it saw as having the political motivation to be potentially interested in such ideas. It barely needs stating, but such conduct is completely unacceptable."

A spokesperson for Banque Havilland said in response to the FCA statement: "Banque Havilland has received an FCA decision notice proposing a financial penalty in relation to historic allegations of misconduct during a short period in 2017, the details of which have already been well-publicised.

"The bank is disappointed in the decision reached by the FCA and does not accept that it is directly liable for the actions of the individuals implicated in the criticised activity, who have long since left the bank.  After careful consideration, the bank has referred the FCA's decision to the Upper Tribunal, which is an independent Court, to determine the matter. 

"The bank has taken measures to ensure that any consequences will not significantly affect the bank's financial position.

"The bank is not subject to any other action arising from these events and is fully focused on delivering its agreed strategy for customers."