“History may not repeat itself. But it rhymes”; misconduct in wholesale markets

21 July 2022

We are delighted to have assisted the Financial Markets Standards Board with its second edition of the Behaviour-pattern Conduct Analysis (BCA). This is an important study of misconduct in global wholesale financial markets spanning over 200 years.

The study shows that there are in fact a limited number of core patterns of market misconduct, which repeat and recur over time and adapt to new technology and market structures. The second edition of the BCA updates the original analysis to include recent cases, a broader jurisdictional analysis and an application of the analysis to new digital asset classes.

This work remains as relevant as ever in the light of conduct risks presented by rapid technological development and external market forces. We have no doubt that it will continue to provide an important reference point for firms and advisers operating in wholesale markets.