Employees of Odey Asset Management, including eponymous founder Crispin Odey, are no longer able to access any funds they have invested with the firm without the prior written consent of the Financial Conduct Authority.
According to the FCA register, Odey Asset Management and Odey Wealth Management will be restricted from transacting any instructions initiated by clients who are also "controllers, members, officers or employees" of the firms.
Clients who are not related to the firms in this way will be able to continue instructing the firm on transactions, which would be considered the "ordinary course of business", according to the regulator.
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The firms have been restricted from disposing of, withdrawing, transferring, dealing with or diminishing the value of any assets, unless considered the "ordinary course of business" or if the FCA grants written consent.
The regulator added the assets restriction "does not apply to monetary payments or the disposal of assets made by the firms in the ordinary course of business, or amounting to no more than £20,000 - whether as a single transaction or a combination of related transactions".
The restrictions are effective from 17 June for Odey AM and 18 June for Odey WM.
Both firms are also required to provide a weekly update to the FCA with a list of its bank accounts and respective balances.
Other actions permitted in the ordinary course of business include: Payments of funds to suppliers or third parties in satisfaction of contractual and legal obligations; usual and proper salary payments agreed before 16 June 2023; the transfer or disposal of the firm's or investment management's agreements to a third party, with one working day's prior written notice.
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The FCA has also restricted the following payments: "Unusual or significant" amounts to the firm's controllers, members, officers, employees or any connected persons, including any management or performance fees; capital distributions, excluding a return of capital that may be payable to a firm member within 12 months of departure, if the obligations were agreed prior to 16 June 2023; any gift or loan to any party; any payments made as part of a financial restructuring, reorganisation or sale of the firm, excluding to third parties.
Internally, senior management function holder approval is now required for transactions unless made "in accordance with established decision-making procedures".
The FCA has also explicitly required the firms to "secure all books and preserve all information and systems which may be relevant to demonstrating compliance" with the new restrictions.