UT (Tax & Chancery) UT-2022-000134 UT-2022-000135 UT-2022-000137 - [2025] UKUT 00214 (TCC)

There is a broad level of consistency to the explanations given by Mr Urra and Mr Sheth from their first interviews with Compliance to their disciplinary interviews. The explanations are not entirely clear, they did not explain that this was a strategy which had been designed by Mr Urra or that these orders that were said to be to establish a basis position were being placed at the same time as a hedging order in the opposite direction.

Whilst Mr Lopez’s Anticipatory Hedging Strategy does not emerge clearly from the note of his interview with Compliance, Mr Lopez’s explanations were consistent between the disciplinary interview with HR and the interview with the Authority, although he did not clearly explain any link with his focus on medium-sized RFQs and attempts to predict patterns in these RFQs which were received by the Desk.