A Portland-stone colonnade in the City of London at dusk.

For solicitors · For banks

FX market-abuse and surveillance specialist.

Manuel Mifsud

Global FX SME, market abuse and trade surveillance, currently in the first line of defence (1LOD), previously in the second line (2LOD), at leading global and UK FX market-making institutions. Formerly Senior Partner and Head of Trading at a hedge fund managing more than $1 billion, and before that Head of EMEA FX exotic/structured products and vanilla derivatives at a North American investment bank.

Expert evidence for solicitors. Independent review for banks of their own trades. Foreign exchange is the specialist market.

Solicitors and counsel

Expert evidence when the file involves currencies, options, whether a price was a genuine market, or a bank’s surveillance of its traders. You do not need to already know the product — or which kind of financial expert to instruct.

Banks and in-house teams

Independent review of your own alerts and trades. Whether a compliance closure is supported by the orders underneath it. What a senior stakeholder should be told. Internal investigations and lookbacks.

Manuel Mifsud, principal of FX Expert Services

The expert

Manuel Mifsud

FX market-abuse and surveillance specialist

Career path

Current

Global FX SME, market abuse and trade surveillance, first line of defence (1LOD)

Leading global and UK FX market-making institution. Independent review of alerts closed by the second line — from the orders and trades, not the write-up — and that conclusion to senior stakeholders.

Previously

Global FX SME, market abuse and trade surveillance, second line of defence (2LOD)

Leading global and UK FX market-making institution. Global trade and communications surveillance. QA of alert closures, STORs and market observations to the FCA, and the design of manual surveillance for FX.

Earlier

Senior Partner / Head of Trading

Hedge fund managing in excess of $1 billion. Day-to-day running of a fixed-income relative-value book. As CIO, the fund’s strongest risk-adjusted years.

Earlier

Proprietary trading

Sell-side, London. Built and ran trading teams. Execution across electronic platforms, DMA and internal crossing.

Earlier

Head of EMEA FX exotic/structured products and vanilla derivatives

North American investment bank, EMEA. Youngest managing director at that bank at 27. Helped create complex FX barrier structures that remain widely used.

Currently accepting instructions. Current and former employers are disclosed at conflicts the same day.

Desk, book, both lines. One specialist.

Manuel Mifsud is Global FX SME in the first line of defence (1LOD) and second line of defence (2LOD) at leading global and UK FX market-making institutions, reviewing the bank’s own trades and alerts. Before surveillance he headed EMEA FX exotic/structured products and vanilla derivatives at a North American investment bank, was Senior Partner / Head of Trading of a fund managing in excess of $1 billion, and a senior portfolio manager. That is the dealing room, the book, the second line and the first line — the same underlying activity, seen from several sides.

Specialist experience at the intersection of FX dealing, market-abuse surveillance and first-line / second-line review. Instructions are taken personally. If the file will not bear the opinion asked, we say so before a report is written.

Market abuse & surveillance

You may not yet know which expert you need

Many solicitors in financial disputes have never stood on a dealing desk. LOD means “line of defence” — how a bank splits the work of watching its own traders. If any of the following is the file, write. The first call is to see whether it sits here.

  • Currencies, options, barriers, or whether a price was a genuine market
  • A bank’s surveillance of its own traders
  • An alert closed by compliance that needs an independent view
  • Market abuse or manipulation, even if it is not obviously an FX file

Plain English

Terms a solicitor should not have to guess

FXForeign exchange
The market in which one currency is bought and sold for another. The specialist area of this practice.
1LODFirst line of defence
LOD means line of defence. The first line is the business itself — here, independent review of the bank’s own trades and alerts.
2LODSecond line of defence
Compliance and surveillance, sitting independently of the dealing desk. Not the traders reviewing themselves.
MARMarket Abuse Regulation
The UK and EU rules on insider dealing, manipulation and unlawful disclosure.
STORSuspicious transaction and order report
A report a firm must send to the FCA without delay once it has reasonable suspicion of market abuse. Closing an alert is not the same as deciding no STOR is due.

Who we work with

Solicitors, counsel, banks and in-house teams

The visitor should recognise the practice immediately: this is for people who instruct experts, and for banks who need an independent view of their own file.

  • Commercial litigation solicitors
  • Financial-services disputes teams
  • Regulatory lawyers
  • Counsel
  • Banks and financial institutions
  • In-house legal teams
  • International arbitration teams

What we are instructed on

Practice

Currency markets are the core. Market abuse — including a bank’s own files — is instructed more widely, because the surveillance work is not limited to FX.

All practice areas
An empty FX options desk after hours: currency screens, blotter and a cooling cup.

The work

What the market would have done.

A barrier option, a last-look fill, a first-line review of a surveillance alert: the question is almost always market practice on the day, not a textbook rate. We reconstruct the desk — or the bank’s own surveillance file — and we say what the data will support.

FX barriers

Chasing a one-touch

A one-touch digital that paid after a large print in a thin market. Whether that print was a good barrier under the confirmation — source, cut, continuous observation — and whether the tape was a market or a chase.

FX barriers

Knock-out of a reverse knock-out

Whether a print in the observation window was a good barrier under the confirmation: source, cut, continuous or discrete, and what a dealer who had run those books would have treated as a print.

Market abuse

Independent review of a surveillance closure

A bank’s compliance team has closed an alert. The business wants an independent view from the actual orders and trades — not from the compliance write-up. Whether the activity is consistent with legitimate market behaviour or may indicate abuse.

Market abuse

Spoofing, layering and wash trading

Orders placed and cancelled in a pattern that may have been intended to move a thin FX price. Read from the order book, not from the alert text: size, life of the order, and whether a genuine strategy explains it.

Spot FX

Last look on a spot order

Whether a rejection inside the last-look window was consistent with price-and-credit checking, or with holding the order long enough to trade against it.

Spot FX

Internalisation of a client order

Whether the desk filled from its own book at a genuine market, or used the order as a source of last-look flow. What a client of that standing would have been shown.

Illustrative questions
After-hours screens with a cool teal glow.

How an instruction runs

From conflicts to oral evidence

  1. 01

    Conflicts

    Names of parties, counsel, banks and known related entities — including current and former employers. A conflicts check the same day where we can.

  2. 02

    Scope

    The market questions the court actually needs answered — a barrier, a last-look fill, an independent review of a surveillance alert — and the questions it does not.

  3. 03

    Evidence

    Tickets, blotters, confirmations, order and trade data, chat and voice. We say early if the file cannot support the opinion asked.

  4. 04

    Report

    A CPR Part 35 (or arbitral equivalent) report: assumptions, method, opinion, and the limits of that opinion. Drafts are for factual correction, not advocacy.

  5. 05

    Oral evidence

    Available to give oral evidence in the Commercial Court, the High Court and international arbitration if required.

Independence

The duty is to the court — or, on a bank instruction, to an independent conclusion the file will support. Current and former employers are disclosed the same day, on the conflicts page, before papers are sent. Matters involving those institutions, confidential information from employment, or any file that cannot be taken independently, are declined.