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UK compliance officer fined in misleading bond promotion

Alison Moran, the compliance officer at Catalyst, has been fined £20,000 for her part in the non-compliant selling of structured products.
Alison Moran, the compliance officer at Catalyst, has been fined
£20,000 for her part in the non-compliant selling of structured
products.
She held controlled function 10 between 3 August 2006 and 7
October 2011. She was fined under s66 Financial Services and
Markets Act 2000 (as amended), which deals with the FCA's
disciplinary powers, and under APER Statement of Principle 6,
which states that an approved person performing an accountable
significant-influence function must exercise due skill, care and
diligence in managing the business of the firm for which he is
responsible in his accountable function. Catalyst, for its part,
transgressed against principle 1 (a firm must conduct its
business with integrity) and principle 7 (a firm must pay due
regard to the information needs of its clients, and communicate
information to them in a way which is clear, fair and not
misleading). APER is the Code of Practice for Approved
Persons.
Catalyst was the primary distributor of ARM bonds (structured
products issued by a Luxembourg entity, ARM) in the UK between
2007 and 2009. The underlying assets of such bonds were senior
life settlements purchased in the United States. Catalyst
promoted and distributed ARM bonds to investment intermediaries
and independent financial advisers in the UK, who in turn
promoted and sold them to private investors. Ms Moran turned a
blind eye to licensing problems.