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Release Date: 6th August 2013

To access the original FCA document, click here.


Vandana Madhukar Parikh has been fined £45,673.50 by the Financial Conduct Authority (FCA) for failing to exercise due skill, care, and diligence in her role as an approved person, breaching Principle 2 of the Authority’s Statement of Principle and Code of Practice for Approved Persons. This action follows her engagement with a client, Mr. Goenka, who was involved in market manipulation attempts specifically concerning auction trading and the impact of orders on the price of securities.

The case stems from Mrs. Parikh’s involvement in explaining the manipulation processes to Mr. Goenka, despite her suspicions about his motives related to an underlying structured product. Mrs. Parikh failed to adequately challenge Mr. Goenka’s actions or make sufficient enquiries to ensure that no risk of market manipulation existed, thereby indirectly facilitating Mr. Goenka’s potentially abusive market activities.

Key takeaways for other firms from this enforcement action include:

  1. Vigilance and Due Diligence: Firms must ensure that their employees exercise vigilance and due diligence, especially when there are indications of a client’s ulterior motives that could lead to market abuse.
  2. Adequate Enquiries and Challenges: It is crucial to challenge suspicious client activities and conduct adequate enquiries to confirm the legitimacy of their actions. Failure to do so can implicate the firm and its employees in regulatory violations.
  3. Training and Awareness: Ensuring that all staff, particularly those in significant influence functions, are adequately trained and aware of their responsibilities under market abuse regulations is essential.
  4. Compliance and Oversight: Robust compliance systems and oversight mechanisms need to be in place to detect and prevent any forms of market manipulation or other abuses, safeguarding both the firm’s and its clients’ interests.

This case underscores the importance of maintaining high standards of regulatory conduct to protect the integrity of the financial markets and uphold consumer trust.

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