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

Each of the Traders had received training at MHI on market manipulation and market abuse.

Each of the Traders had completed MHI’s online “Market Conduct 2015” training, which required those being trained to complete exercises and answer questions as they progressed through the module. That training included an example headed “Adding some liquidity” as follows:

“A trader is looking to unload 3,000 shares of QuestQuo plc, a relatively illiquid stock with an average order size of 1,500 shares on either side of the order book. As the price looks a little low, the trader placed an order to buy 100,000 shares just under the lowest bid on the market. As a result of the large order, there is an uptick in the market price, upon which the trader places an order to sell his 3,000 shares into the market, which is fully executed. The trader then immediately deletes his buy order.”

The answer on the following slide is then:

“Making trades purely to manipulate market prices is prohibited. The traders’ behaviour is known as spoofing/layering and is very likely to be seen by the regulators as market manipulation.”

The Tribunal finds that the Traders understood the principles underpinning the rules against market abuse, understood what spoofing was, and that spoofing (and indeed placing any orders without an intention to trade) constituted market abuse.