For solicitors · For banks · UK
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. Senior Partner of a hedge fund managing in excess of $1 billion. Head of EMEA FX exotic/structured products and vanilla derivatives at a North American investment bank. Independent review of a bank’s own currency-market alerts — from the trades and orders, not from the alert text. Expert evidence under CPR Part 35 when a solicitor instructs.
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.
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.
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.
Proprietary trading
Sell-side, London. Built and ran trading teams. Execution across electronic platforms, DMA and internal crossing.
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.
Large banks split market-abuse work into two lines. This practice has sat in both — which is why a solicitor, or a bank instructing an independent review, can test the opinion against how the file is actually built.
Current role at a leading global and UK FX market-making institution: Global FX SME. Independent conclusion from the underlying orders and trades — not from the second-line write-up. Whether the activity is consistent with legitimate market behaviour or may indicate abuse, and what a senior stakeholder should be told.
Previous role at a leading global and UK FX market-making institution: Global FX SME. Specialist review of alert quality, rationale and evidence, STORs (suspicious transaction and order reports) and market observations, and the design of manual surveillance for foreign exchange. Robust challenge where the logic will not bear the close.
We do not decide liability. We set out the market facts on which the court, the firm or the regulator can.
The file
For a solicitor who has never sat in that queue: the useful question is not whether an alert was closed. It is whether anyone reconstructed the orders, or closed the story the platform told.
01
A surveillance scenario fires — spoofing, layering, wash trading, ramping, an off-market print, activity into a fix, last look, a lexicon hit in chat — or someone on the desk, in the first line or in the second line, spots it by eye. Sometimes the first notice is an exchange query, a client, or the FCA.
02
The platform opens a case, scores it, and drops it in a second-line (2LOD) queue. A clock starts. Under the Market Abuse Regulation, if suspicion is later formed, a STOR must go to the FCA without delay. This is not an open-ended file.
03
Duplicate, known false positive, or real work? Market-making inventory, a disclosed client fixing order, a hedge into a barrier, thin holiday liquidity — all can look like abuse on a crude scenario. Weak scenarios waste months. Weak triage closes the interesting ones.
04
If it survives triage, the analyst should pull the orders and trades, not the narrative the machine wrote. Life of the order, size, venue, cancels, fills, the other side of the book, the pair, the time of day. Chats and voice if the typology needs them. The question is always: was this the market of that second, or an attempt to make a market that was not there?
05
The first line (1LOD) can explain what the desk thought it was doing. They must not write the conclusion. Independence is the point of the second line sitting off the desk.
06
Close as legitimate or a false positive. Close as explained, with residual risk — those should be QA’d. Escalate: internal investigation, employee referral, a market observation, or a STOR. Or keep the file open and watch.
07
This is the document a solicitor later sees. It should say what was looked at, what was not, and why the activity was or was not consistent with legitimate behaviour. In practice, many closures describe the alert, not the orders. That is the gap a first-line independent review is for: read the tape again, ignore the write-up, and say whether the closure is supported.
08
Sample QA inside the second line. Sometimes the first line independently samples second-line closures. Scenario tuning. Record keeping. A close is not the end if new facts appear — suspicion can still crystallise, and a STOR can still be due.
Typologies
Orders placed and cancelled in a pattern that may have been intended to move a thin FX price. Read from the order book: size, life, and whether a genuine strategy explains it.
Prints with no change of beneficial owner, or a sequence into a close, a fixing or a valuation point. Whether the activity was hedging or an attempt to set a price that was not the market.
A print away from the contemporaneous bid and offer. Size, pair, time of day, and whether a dealer would have treated that price as a market or as a transfer.
Activity in the minutes before a disclosed client FX fixing. Whether the desk was managing the risk, or positioning on the other side of it.
Orders clustered in a benchmark window. Methodology of the fix, the client instruction, and whether the tape is a genuine fixing or an attempt to move the print.
Information from a rejected last-look order used to trade on another venue. Market practice on what last look may be used for, and what it may not.
What happened between a suspicious pattern firing and the alert being closed. Whether anyone reconstructed the orders, or closed the story the platform told.
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.
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.
A cluster of aggressive prints into a quiet book, a fixing window or a barrier. Whether the tape is a genuine interest in that size, or an attempt to force a price through a level.
Whether the pattern met the threshold for a suspicious-transaction report or a market observation to the FCA. The evidence in the FX tape, not the narrative in the alert.
Orders clustered in a WMR, ECB or EM fixing window. Methodology of the benchmark, the client instruction, and whether the tape is a genuine fixing or an attempt to move the print.
The instruction, when a solicitor instructs, is expert evidence. The proposition is narrower: an FX market-abuse and surveillance specialist who has sat on the desk, run the book, and worked both lines of defence. Search terms this page is meant to meet include market-abuse expert witness, FX market-abuse expert, market surveillance expert, FX trading expert, and market-manipulation expert. Banks instruct for independent review of their own trades.
If the file is conduct in the market — whether or not it is obviously FX — write. Conflicts, including current employment at NatWest Markets and a former second-line role at UBS, are disclosed before any papers are sent.
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