On 12 November, BNN Bloomberg reported that the FCA has imposed its second penalty in relation to the Cum-Ex tax scandal, fining Sunrise Brokers LLP more than £600,000 pounds over its relationship with hedge-fund manager Sanjay Shah, and for failing to control money laundering and trading risks.  The firm was given a 30% discount on the size of its overall penalty for cooperation.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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