London’s Upper Tribunal has largely upheld a decision by the UK’s Financial Conduct Authority (FCA) to sanction Luxembourg-based Banque Havilland, now operating as Rangecourt SA, and two former employees for conduct related to a plan to potentially destabilize Qatar’s currency during the 2017 Gulf diplomatic crisis. While the tribunal reduced the financial penalty levied against the bank, it affirmed findings of misconduct and upheld bans for two individuals.
The tribunal reduced the fine imposed on Banque Havilland from an initial £10 million to £4 million, stating that the FCA’s original figure appeared “arbitrary.” However, the judgment, delivered on , confirmed that the bank’s actions lacked integrity. The case centered on a presentation outlining strategies to pressure Qatari bonds and weaken the Qatari riyal, a plan developed amidst a blockade of Qatar by neighboring Gulf states.
The FCA argued the presentation, created in 2017, was intended as a marketing tool to attract business from Mubadala Investment Company, the sovereign wealth fund of Abu Dhabi. The tribunal agreed that the firm and its personnel failed to act with integrity in both the creation and dissemination of the document. Despite the tribunal noting the strategy was “never implemented and there was no actual market manipulation,” it rejected the bank’s defense that the presentation was a private project of its owners, the Rowland family, and not conducted on “bank business.”
Two former employees were also subject to the tribunal’s ruling. Edmund Rowland, former London branch CEO, saw his £352,000 fine and lifetime ban from regulated financial services upheld. Vladimir Bolelyy, a former analyst, also retained his £14,200 fine and prohibition order. The tribunal found both individuals, along with the bank, were responsible for “a very serious breach” of UK rules, describing the conduct as “deliberate and encouraged the commission of financial crime and market misconduct.”
The controversial presentation, initially referred to internally as “Setting fire to the neighbour’s house fund,” was drafted by Bolelyy and detailed a plan to attack the Qatari riyal and potentially break its peg to the US dollar through manipulative trading strategies targeting Qatari sovereign bonds. The presentation was reportedly created in response to a request from Mubadala for strategies to mitigate risk associated with its holdings of Qatari bonds.
The tribunal clarified it was “not satisfied” that the presentation was ever actually delivered to Mubadala. Despite this, the tribunal rejected the argument that the bank should not be held accountable for the presentation’s content. Claire Cross, a partner at law firm Corker Binning and former FCA official, emphasized that firms cannot avoid responsibility by claiming misconduct was informal, unsanctioned, or lacked direct supervision.
The FCA’s Executive Director of Enforcement and Market Oversight, Steve Smart, stated that Banque Havilland, Rowland, and Bolelyy “had a plan to seriously damage the Qatari economy” and that it was “right that they have been held to account.”
Banque Havilland, founded in 2009 by David Rowland, a former Conservative party treasurer and advisor to Prince Andrew, has undergone significant changes in recent years. Following the FCA fine and the withdrawal of its Eurozone banking license by the European Central Bank in 2024, the lender has scaled back its operations, including winding down its UK business and selling its Monaco-based arm.
While the tribunal found no evidence that David Rowland was aware of the Qatar presentation, it determined that his son, Edmund, was “seeking to benefit the commercial interests of the bank and of the Rowland family generally.” The tribunal also dismissed David Rowland’s claim that the FCA had a “preconceived case theory” or was acting on behalf of Qatar.
Rangecourt, along with legal representatives for Edmund Rowland and Bolelyy, did not respond to requests for comment regarding the tribunal’s decision.
