| Link(s): | Warning Notice Statement 24/4 |
Context
On 18th September 2024 the FCA gave Crispin Odey a warning notice proposing to take action in respect of the conduct summarised in the statement. The FCA considers that, during the period from 24th December 2021 to 17th November 2022, Mr Odey (who was a certification employee at Odey Asset Management LLP (OAM) and at times during this period held Senior Management Functions) breached Individual Conduct Rule 1 of the FCA’s Code of Conduct which required him to act with integrity.
Key points to note and next actions
- A warning notice is not the final decision of the FCA. The individual has the right to make representations to the Regulatory Decisions Committee which, in the light of those representations, will decide on the appropriate action and whether to issue a decision notice.
- In February 2021, OAM gave Mr Odey a Final Written Warning in relation to inappropriate behaviour. In late 2021, OAM scheduled a disciplinary hearing to consider whether Mr Odey had breached the Final Written Warning.
- The FCA considers that, during the relevant period, Mr Odey demonstrated a lack of integrity in that his actions were deliberately designed to frustrate OAM’s ongoing disciplinary process into his conduct, in order to protect his own interests, and showed a reckless disregard for OAM’s governance and caused OAM to breach certain regulatory requirements.
- In addition, Mr Odey’s behaviour towards both OAM and the FCA lacked candour. He used improper means to protect his own interests and achieve his objectives; the reasons he gave for his dismissal of OAM’s Executive Committee, and his conduct in his dealings with the FCA, also support the finding that he lacks integrity.