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OCC to fine and bar two FOREX traders

Fine Amount: 
$10 million
Penalty Type: 
Issued by: 

The OCC has issued notices of charges for prohibition and notices of assessment of civil money penalty against Richard Usher, former Head of G10 Spot Trading at JPMorgan Chase Bank, N.A., and Rohan Ramchandani, former Head of European Spot Trading at Citibank, N.A. The OCC also fined Usher and Ramchandani $5 million each for violating the Sherman Antitrust Act, engaging in unsafe or unsound practices, and breaching their fiduciary duties related to their conduct in the foreign exchange (FOREX) market.

The OCC found that beginning in as early as December 2007 and continuing until at least January 2013, Usher and Ramchandani were FOREX spot traders with their respective banks who primarily traded the euro, including the euro/U.S. dollar (EUR/USD) currency pair. Throughout the relevant period, Usher and Ramchandani engaged in near daily conversations with each other and other EUR/USD spot traders at competing financial institutions in a permanent electronic chat room that referred to itself, and was known in the market, as the “Cartel.” Through their participation in the Cartel chat room, Usher and Ramchandani engaged in unsafe or unsound practices, breached their fiduciary duties, and entered into and engaged in a conspiracy with other euro traders in the chat room to suppress or eliminate competition and increase, decrease, fix, maintain, or stabilize prices in the FOREX Spot Market.

Concurrent with the OCC’s enforcement action, the Department of Justice also issued indictments against Usher and Ramchandani for violations of the Sherman Antitrust Act. In addition, the Federal Reserve announced enforcement actions against another trader in the Cartel chat room. Usher and Ramchandani may request a hearing challenging their respective notice of charges for prohibition and notice of assessment of civil money penalties.

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