Compliance Monitor
Conflicts of interest turbulence for Greensill-linked firm
An FCA warning letter and a signedattestation of compliance did not deter GAM International Management from multiplefailures to manage its conflicts of interest appropriately. Denis O’Connordissects the enforcement notices against the firm and investment directorTimothy Hayward.
Denis O’Connoris a fellow of boththe Institute of Chartered Accountants in England & Wales and the CharteredInstitute of Securities and Investment. He was a member of the British Bankers’Association Money Laundering Committee from 2003-10 and a member of the JointMoney Laundering Steering Group’s board and editorial panel between 2010 and2016. He has been a frequent speaker at industry conferences on financial crimeissues, both in the United Kingdom and abroad.

The Financial Conduct Authority has fined anasset management firm GAM International Management Limited (GIML) £9,103,523and
Timothy Hayward, a former investment director and business unit head atGIML, £230,037 over their failure to manage conflicts
of interest properly fromthree transactions, two of which were with Greensill Capital UK. [1] Potentialincentives were offered
that would benefit GIML or its parent company. Althoughthese were not taken up, they were not dealt with appropriately.