Rangecourt SA & Ors v Financial Conduct Authority (FINANCIAL SERVICES - whether firm failed to conduct its business with integrity - whether director and employees lacked integrity in preparing a document describing a strategy of market manipulation - whether part of the firm's business - whether conduct of the individuals could be attributed to the firm) [2026] UKUT 47 (TCC) (03 February 2026)

Executive summary

The Upper Tribunal considered references against FCA Decision Notices arising from a 2017 document that all parties agreed was wholly improper and that purported to describe a market-manipulation strategy to pressure the Qatari currency. The case addressed whether Rangecourt SA (formerly Banque Havilland), Mr Edmund Lloyd Rowland, and Mr Vladimir Bolelyy had acted without integrity, whether the conduct could be attributed to the firm, and whether the FCA’s penalties and prohibition orders were justified.

Key points

• Parties: Rangecourt SA (formerly Banque Havilland), Edmund Lloyd Rowland, Vladimir Bolelyy, and the FCA; David John Rowland was a third-party rights applicant.
• Core issue: a 2017 document described a strategy of market manipulation aimed at the Qatari Riyal and was said by the FCA to have been used to market the bank to Mubadala Investment Company.
• The bank disputed that the conduct engaged Principle 1 or was part of its business; Mr Rowland and Mr Bolelyy disputed allegations of lack of integrity and fit-and-proper findings.
• The source text states only that Decision Notices had imposed a £10m penalty on the bank, £352,000 on Mr Rowland, and £14,200 on Mr Bolelyy, plus prohibition orders for the individuals.
• The text expressly notes that no allegations were made and no adverse findings were sought against Mubadala, and no criticism was made of David John Rowland in the introductory section.
• Sanctions/geopolitical angle: the factual backdrop includes contemporaneous UAE sanctions on Qatar, making the document relevant to conduct intersecting with sanctions-era geopolitical pressure and market manipulation risk.

Why it matters

The case shows FCA scrutiny where a private bank’s materials allegedly linked geopolitical sanctions conditions to a strategy of market manipulation. For sanctions and sovereign-risk audiences, it is a reminder that conduct around sanctioned-state disputes can trigger integrity, fit-and-proper, and governance consequences even absent direct sanctions-breach allegations.

Implications

Compliance teams should treat politically charged trading ideas, client pitch materials, and internal strategy memos as potential enforcement evidence if they contemplate or signal improper market conduct. For litigation strategy, the attribution question and whether the conduct was part of the firm’s business are central to resisting firm-level liability and penalty/prohibition outcomes.