Market abuse and surveillance
Large banks split this work in two. The first line of defence (1LOD) is the business reviewing its own trades. The second line (2LOD) is compliance and surveillance, sitting independently of the desk. This practice has sat in both. As first line: an independent conclusion from the orders and trades — not from the compliance write-up. As second line: review of alert quality, STORs (suspicious transaction reports) and the design of surveillance. Typologies include insider dealing, off-market prints, wash trading, ramping, layering and spoofing. Currency markets are the specialist area; the same eye is instructed on market-abuse files more widely. We do not decide liability. We set out the market facts on which the court, the firm or the regulator can.
Market abuse & surveillance landing pageFX barriers
Barrier determination is a specialism of this practice, not the whole of it. Source, cut, continuous or discrete, American or windowed — and what a dealer who had run those books would have treated as a print. Manuel headed EMEA FX exotic/structured products and vanilla derivatives and helped create complex barrier structures that remain widely used. We reconstruct the path, the confirmation and the market of that day, and we say whether the knock was good.
Vanilla and exotic options
Beyond the barrier sits the rest of the options book: vanillas marked off the wrong surface, a digital that paid when it should not, a TARF or collar torn up mid-life. We value to the close-out date in the size and the pair of that day, and we say whether the number was a market or a penalty.
Spot FX
Spot instructions turn on market practice at the time of the order: the published mid, the dealer’s spread, last-look windows, and whether an internaliser’s price was a genuine offer to deal. We reconstruct the tape from tickets, blotters and venue data, and we say what a competent dealer would have done — not what a textbook mid implies after the fact.
Forwards and FX swaps
Forward and swap disputes are usually about points, not the spot. We examine the curve, the points quoted for the tenor, historic rolls, and the replacement cost of an early close. Instructions include corporate hedges that were torn up, interbank books that were transferred, and arguments over whether a quoted close-out was a market price or a penalty.
Non-deliverable forwards
An NDF is only as good as its fixing. We look at the source named in the confirmation, the fallbacks, the local onshore market that day, and whether a disruption event was real or convenient. Typical files involve BRL, KRW, INR, TWD and other EM pairs where the onshore print and the offshore NDF can part company.
Valuation and close-out
Close-out is not a mid from a screen. It is the cost of replacing the trade in the size, pair and tenor of that day, with the credit and documentation of the parties. We reconstruct a dealing-room close-out: quotes obtained, quotes not obtained, and the difference between a bid for a small ticket and a bid for a residual book.
Hedge-fund and proprietary books
Instructions of this kind sit between the strategy and the tape. As Senior Partner / Head of Trading of a hedge fund managing in excess of $1 billion, Manuel has run FX derivative books and day-to-day trading in a fixed-income relative-value fund. The opinion is how that book would have been traded, hedged and unwound — not how a textbook says it should have been.
Best execution and dealing practice
Best-execution instructions ask how the desk treated the order: agency or principal, displayed or not, and whether the fill was the market available to a client of that standing. We compare the fill to contemporaneous prints, to the dealer’s own book, and to what a reasonable e-FX or voice desk would have shown.