Niall Hearty of financial crime specialists Rahman Ravelli assesses the situation.

The UK's Financial Conduct Authority (FCA) has said in a recently-published warning notice that it intends to take enforcement action against a Luxembourg-based private lender.

The FCA has told Banque Havilland that it plans to pursue the bank and several of its former employees over what it calls the promotion in 2017 of "manipulative trading practices" that were designed to harm Qatar's economy.

Banque Havilland is reported to have said it will challenge any action brought against it by the FCA. Any action has to be approved by the FCA's internal regulatory decisions committee.

The government of Qatar brought a lawsuit against Banque Havilland three years ago. Qatar claimed that Banque Havilland conspired with others to damage the country's economy through a trading strategy that aimed to force down the value of its sovereign bonds. This legal action has reportedly been concluded in a confidential settlement.

Although the FCA internal process is ongoing in this case, such warnings by the FCA are usually seen as a shot across the bows for the body involved - they are a statement intended to persuade the body to change its course of action. Banque Havilland is, however, challenging the matters referred to by the FCA.

It is now a question of waiting to see whether the FCA's internal regulatory decisions committee concurs with the contents of the warning notice and takes enforcement action against the bank.

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