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ARTICLE · 01 FEBRUARY 2018

Penalty For BAML "Algo-Baiter"

Mishcon de Reya LLP
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Paul Axel Walter has been fined £60,090 by the FCA for committing market abuse in terms of s.118(5) of the Financial Services and Markets Act 2000 (FSMA).

United KingdomFinance and Banking
Adam Epstein
Adam Epstein

Paul Axel Walter has been fined £60,090 by the FCA for committing market abuse in terms of s.118(5) of the Financial Services and Markets Act 2000 (FSMA). The conduct took place between 2 July 2014 and 8 August 2014 (the Relevant Period) and prior to the implementation of the Market Abuse Regulation which now sets down the law relating to market abuse. 

Walter was an experienced and senior bond trader, working at Bank of America Merrill Lynch (BAML). His relevant trading during the Relevant Period related to Dutch Government Bonds (DSLs).  By way of background, the Dutch State Treasury appoints Primary Dealers in relation to DSLs. Primary Dealers are, amongst other matters, required on a daily basis to make available a certain level of liquidity.  On the day before the start of the Relevant Period, BrokerTec became a designated trading system which meant that Primary Dealers in DSLs could meet their obligations by quoting on BrokerTec. BrokerTec is an electronic

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