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Syed Rahman assesses the significance of the first Cum-Ex action taken by a regulator not based in a country affected by the scandal

Author: Syedur Rahman  13 May 2021


When the Financial Conduct Authority (FCA) fined the broker Sapien Capital £178,000 for money laundering failings it was the first Cum-Ex action taken by a regulator not based in a country hit by the share selling scandal.

Rahman Ravelli’s Syed Rahman wrote an article, which was published by Law360, that explained why the approach taken by the FCA in the case was so important. In his piece, Syed emphasised that the case may have far greater significance than is immediately apparent.

He outlined the details of the case and the reasons why Sapien was fined. But he also detailed why the action that the FCA took can be viewed as using a “back door’’ approach to bringing action against those involved in Cum-Ex.

The Sapien case did not have to touch on the legality of Cum-Ex and there was no requirement to prove that the alleged trades that were the focus of the investigation actually occurred. It showed, Syed argued, that the authorities have another route they can use to target those they believe were involved in Cum-Ex.

Syed added that the scale and multinational nature of investigations into Cum-Ex mean it will take a long time for it to be fully resolved. Yet the Sapien case may be the first indicator of a strategy that could be employed by regulators who cannot take the most direct action against the Cum-Ex perpetrators.

Syed's article featured in Law360. (Subscription required)

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Syedur Rahman is known for his in-depth experience of serious fraud, white-collar crime and serious crime cases, as well as his expertise in worldwide asset tracing and recovery, civil recovery, cryptocurrency and high-stakes commercial disputes.

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