OCC administrative actions against Rohan Ramchandani, former head of European FX Spot Trading at Citibank, and Richard Usher, former head of EMEA FX Spot Trading at JPMorgan Chase

Analysis Group was retained on behalf of Rohan Ramchandani and Richard Usher, former foreign exchange (FX) traders at Citibank and JPMorgan Chase, respectively, both accused by the US Department of the Treasury’s Office of the Comptroller of Currency (OCC) of cartel conduct in the FX market through a Bloomberg chatroom.  In an earlier criminal trial in the US District Court for the Southern District of New York, Analysis Group was retained on behalf of the two traders, who, along with a third London-based trader, were cleared of charges that they rigged the spot Euro-US dollar market by sharing information via the chatroom. Following the jury’s acquittal in the criminal trial, the OCC amended its administrative proceedings to drop violations of the Sherman Act but continued to pursue the cartel conduct under the rubric of “unsafe or unsound practices” and breach of fiduciary duties.

An Analysis Group team led by President Pierre Cremieux; Managing Principals Michael Holland, Richard Starfield, and Samuel Weglein; Principal Brian Ellman; Vice President Chris Feige; and Managers Hadrien Vasdeboncoeur and Solvejg Wewel supported three affiliates, each of whom testified in the case. Finance expert Professor Michael Melvin evaluated the chat conversations and trading behaviors; regulatory expert Dr. James Overdahl evaluated any impact on the safety and soundness of the banks resulting from the alleged conduct; and antitrust expert Professor Edward Snyder evaluated whether the alleged conduct was anticompetitive in nature.

After the depositions, and just before the close of expert discovery, the OCC withdrew all charges against Usher and Ramchandani, ending the case.

The case was shortlisted for Global Investigations Review’s “Most Important Court Case of the Year” in 2021.