The Upper Tribunal (Tax and Chancery Chamber) has directed the Financial Services Authority to fine Swift Trade £8 million for layering, the abusive placing of large orders which there is no intention to fill. The FSA fined Swift Trade, a non-FSA authorized Canadian company with global operations, in 2011. In a statement accompanying its decision notice on August 31, 2011, the regulator said: "In the FSA's opinion, between January 1, 2007 and January 4, 2008, Swift Trade's manipulative trading caused a succession of small price movements in a wide range of individual shares on the London Stock Exchange from which Swift Trade made substantial profits … It has not been possible to measure Swift Trade's profits precisely; however, they were in excess of £1.75 million." In its decision the tribunal said Swift Trade's conduct was "deliberate, manipulative market abuse in the form of'layering' and was not undertaken in accordance with recognized market practice".
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