Independent expert evidence in FX and market abuse.

01

FX barriers

Knock-outs, knock-ins, reverse KOs, windowed observation, and whether a print was a good barrier.

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 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.

02

Vanilla and exotic options

Vanillas, digitals, touches, TARFs, collars, and the volatility surface used to close them.

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.

03

Market abuse — 1LOD and 2LOD

Independent review of FX alerts from the trade and order data. 1LOD challenge of 2LOD closures; 2LOD SME on MAR, STORs and the control framework.

The specialism is market abuse in FX, seen from both sides of the control framework. As 1LOD, the work is an independent conclusion from the underlying orders and trades — not from the 2LOD write-up. As 2LOD, it is SME review of alert quality, rationale and evidence, STORs and market observations, and the design of manual surveillance for FX. Typologies include insider dealing, off-market prints, wash trading, ramping, layering and spoofing. We do not decide liability. We set out the market facts on which the court, the firm or the regulator can.

04

Spot FX

Last look, internalisation, bid–offer spreads, and whether a fill was consistent with the market of that second.

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.

05

Forwards and FX swaps

Forward points, broken dates, roll costs, and the close-out of a book when a relationship ends.

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.

06

Non-deliverable forwards

Fixing sources, disruption, emerging-market pairs, and what happens when the published rate is not a market.

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.

07

Valuation and close-out

ISDA 2002, replacement cost of an FX book, and whether the number was a market.

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.

08

Hedge-fund and proprietary books

FX derivative strategies, relative-value structures, and how a book of that kind is actually run.

Instructions of this kind sit between the strategy and the tape. Manuel has managed a $100 million FX derivatives book, helped set up an FX business alongside an existing interest-rate franchise, and run 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.

09

Best execution and dealing practice

Whether an order was worked as a client order, internalised, or used as a source of last-look flow.

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.