On March 2 2016 the Financial Conduct Authority (FCA) announced that it had prohibited Mr Michael Curtler, a former trader at Deutsche Bank, from working in the UK financial services industry for lacking honesty and integrity. This followed a criminal conviction in the United States for his role in a conspiracy to manipulate Deutsche Bank's US dollar London Interbank Offered Rate (Libor) submissions.

Similarly, on April 12 2016 the FCA announced that it had banned Mr Paul White, a former RBS Libor submitter, from conducting any regulated financial activity. The FCA also issued a public censure and stated that White would have received a £250,000 fine were it not for his serious financial hardship. This related to his conduct when submitting Japanese yen and Swiss franc prices to the British Bankers Association for input into the Libor prices.

Subsequently, on April 14 2016 the FCA also prohibited Mr Arif Hussein, a former trader at UBS in London, from any role in regulated financial services. The FCA's decision was based on Hussein's role in influencing UBS's Libor submitters by informing them of his preference for certain pound sterling rates, which were beneficial to his trading positions. Hussein disputes the FCA's decision and the matter has been referred to the Upper Tribunal. While a decision is pending in the Upper Tribunal, the prohibition on Hussein will not be effective.

These bans follow the earlier bans for Libor manipulation of Mr Paul Robson in February 2015 and Mr Lee Stewart in July 2015, both previously employed by Rabobank.

For further information on this topic please contact Kathleen Harris, Stuart Baker, Michael J Atkinson or James McSweeney at Arnold & Porter LLP by telephone (+44 20 7786 6100) or email ([email protected], [email protected], [email protected], or [email protected]). The Arnold & Porter website can be accessed at www.arnoldporter.com.

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