Industry Bar for Former Global Head of FX Trading and Portfolio Manager at Merrill Lynch Investment Mangers, L.P.

In this administrative proceeding against an accomplished investment adviser, the SEC found that respondent defrauded his/Merrill Lynch clients in two ways. The first was by “cherry picking” short term foreign exchange (FX) trades, with profitable trades allocated to favored clients, and losing trades given to unfavored clients. And the second, similar scheme involved delaying the execution and allocation of FX trades that were prompted by client trades of foreign securities, and again preferentially allocating based on subsequent market movement. Respondent was also sanctioned based on these charges in a civil action brought by the SEC.