FCA slaps The TJM Partnership with a £2 million fine for financial crime control failings

The Financial Conduct Authority (FCA) has announced imposing a £2,038,700 fine on The TJM Partnership Limited (in liquidation). The penalty was imposed on the firm for failing to ensure it had effective controls to reduce the risk of financial crime and money laundering in its business.

According to the press release, this the largest fine the regulator has imposed so far in a cum-ex trading related case.

The FCA found that TJM did not have adequate procedures in place to mitigate the risk of fraudulent activities or apply anti-money laundering policies when trading on behalf of clients of the Solo Group. These events took place between January 2014 and November 2015.

The regulator further observed circular pattern of purported trades during this period in thet trading executed by TJM on behalf of the Solo Group’s clients. According to the FCA, these patterns are suggestive of financial crime. Moreover, the trading appears to have allowed the arranging of withholding tax reclaims in Denmark and Belgium.


TJM executed trading in the value of about £59 billion in Danish equities and £20 billion in Belgian equities. The firm received commission of £1.4 million.

In other instances, TMJ also executed transactions with no apparent purpose than to transfer substantial windfall profits of €4.3 million amongst its clients. Thefirm also accepted payment from a third party without appropriate due diligence.

Mark Steward, Executive Director of Enforcement and Market Oversight, said:

TJM allowed itself to become involved in a self-evidently suspicious scheme of circular transactions that looked like shams. TJM demonstrated a complete lack of care and diligence in participating in these transactions of dubious purpose.

The FCA noted that TJM has agreed to resolve all issues of fact and liability. In this way, the firm it qualified for a 30% discount under the regulator’s Settlement Discount Scheme.


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