Ruling Disciplinary Committee | DSI 2015-01

Fine and reprimand for unfair market conduct

DSI Disciplinary Committee ruling 2015-01 dated September 3, 2015

On September 3, 2015, the DSI Disciplinary Committee ruled in a case against a former Senior Money Markets Trader. The complaint concerned the structural inclusion of requests from traders, both inside and outside his own organization, when making Euribor submissions. Own trading positions were also included in these submissions. All this happened without proper internal guidelines, segregation of duties or control, but with the knowledge of management.

Disciplinary Committee ruling

The Disciplinary Committee ruled that this conduct constituted a serious violation of the integrity rules in the Code of Conduct. The fact that management was aware or that there were no clear procedures does not change this. The committee emphasized the registrant’s own responsibility to act with integrity. The complaint was upheld.

Articles DSI Code of Conduct applicable:

7.1.1, 7.1.2, 7.1.4, 7.1.5, 7.3.1 and 7.3.2
The Disciplinary Committee imposed a reprimand and a fine of €1,500. No court costs order was imposed.

Linkage to DSI Core Principles.

• Core principle 1: Take responsibility:
  The registrant had personal responsibility to act with integrity, regardless of the culture or instructions within the organization.
• Core principle 10: Act honestly:
  Knowingly influencing market indicators such as Euribor violates honesty and damages trust in the financial sector.