• falsified his firm's internal records on at least 163 occasions between May and July 2014 by entering false prices in them, thereby overstating his trading profits or conceal his trading losses by approximately US$11 million – a practice known as “mismarking”;
• colluded with traders on a Turkish market to "mark the close" on the last trading day of the months of April, May and June 2014, by creating closing prices that would match his mismarks, the better to avoid the firm’s internal controls and conceal his mismarking;
• instructed a subordinate employee to enter false daily marks on one occasion while Mr Ayhan was out of the office; and
• denied any wrongdoing when the firm questioned him, despite the firm having already presented him with evidence showing that he had mismarked the firm’s records.

The firm carried out an internal investigation and found that Mr Ayhan acted dishonestly and committed gross misconduct under its codes of conduct. It notified the DFSA and co-operated fully with the subsequent regulatory investigation. The DFSA has not punished the firm and does not even mention it by name in its decision notice.