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Charles Flint QC and Andy George acted for Ian Hannam the Chairman of Capital Markets at JP Morgan Cazenove who has been penalised by the FSA for the disclosure of inside information contrary to section 118 (3) of FSMA. The disclosure was made in the course of negotiating a corporate transaction for the purpose of encouraging an offer in the interest of the client who had given implicit authority for the disclosure. The FSA decided that the information was not disclosed in the proper course and constituted inside information, taking a wide view of the effect of section 118C. The FSA recognised that the market abuse was neither deliberate nor reckless and has imposed a penalty of £450,000. The decision has been referred to the Tribunal.

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