Release Date: 29th August 2014

To access the original FCA document, click here.

Summary

The Financial Conduct Authority (FCA) has imposed a fine of £350,000 on Craig Cameron, a former director of Burlington Associates Limited, and banned him from any involvement with FCA authorised firms. The sanction comes after findings that Cameron displayed a lack of honesty and integrity in promoting high-risk unregulated collective investment schemes (UCIS) to retail investors, actions that significantly contravened regulatory standards designed to protect investors.

Cameron’s involvement with Burlington, a London-based financial advisory firm, between May 2003 and January 2009 included the facilitation of three UCIS beginning in early 2005. These schemes, which involved new property developments in Croatia, Bulgaria, and Montenegro, were aggressively marketed to retail investors. Despite regulatory requirements to ensure only eligible investors were targeted, over 800 consumers, many of whom were unsuitable for such high-risk investments, were drawn into investing approximately £30 million. All three schemes eventually failed, resulting in substantial losses for the investors.

In an effort to circumvent restrictions imposed by Burlington’s network principal, which prohibited the promotion and sale of UCIS, Cameron orchestrated an arrangement with Leslie & Nuding (trading as ‘Burlington Funds’ and later known as Leslie & Swallow). Officially, this firm was responsible for investor eligibility checks and the distribution of promotional materials; however, in reality, these tasks were predominantly managed by a firm under Cameron’s direct control. This misleading structure falsely implied that Burlington’s involvement was authorised, thus deceiving both investors and regulatory bodies.

Tracey McDermott, director of enforcement and financial crime at the FCA, criticised Cameron for prioritising potential gains from selling these risky investments over the welfare of investors, highlighting the severe consequences of his actions on the affected individuals.

This case underscores the importance for financial services firms and their representatives to adhere strictly to regulatory guidelines, particularly those designed to protect consumers from unsuitable high-risk investments. Firms must ensure that their business practices are transparent and compliant with regulatory expectations to avoid similar punitive measures. The FCA’s continued focus on such cases serves as a reminder that ensuring the suitability of investment products for consumers is a critical requirement, and failure to do so can result in significant sanctions.

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