Professional Documents
Culture Documents
Neil Roth
BNP Paribas
Oversight of Operational Permanent Control
March 22, 2012
Rogue Traders and Risk Culture
Table of Contents
Purpose 3
Definition of "Rogue Trader" 4
Profile #1: Dany Dattel 5
Profile #2: Nick Leeson 13
Profile #3: Toshihide Iguchi 20
Profile #4: Yasuo Hamanaka 31
Profile #5: John Rusnak 38
Profile #6: Jérôme Kerviel 45
Profile #7: Kweku Adaboli 55
Bad Traders, not Rogue Traders 60
Rogue Trader Heat Map 61
Fraud Diamond 62
Lessons Learned: Shoring Up Defenses 67
Epilogue - Profile #8: William Pullinger 68
Contact Information 72
Disclaimer 73
End of Presentation 74
Purpose
1. The Rogues:
Dany Dattel
Dany Dattel
Dany Dattel
Dany Dattel
Dany Dattel
• Internal auditors approached him about rumors that he had lost huge amounts
of money in Marks versus Dollars. He told them that the position was hedged
with a winning position in Swiss Francs versus Marks. The auditors could not
see the hedge, and reported their findings to management.
• In March 1974, West German regulators sent auditors to evaluate Dattel’s
trading book. They found an unhedged long position of $3.2 billion Dollars
versus 8 billion Marks. This single position was four times larger than Bankhaus
Herstatt’s 2 billion Marks ($800 million) in operating capital.
• Regulators knew that if the Dollar plunged against the Mark, Bankhaus Herstatt
would be insolvent. They tried to find a buyer. Deutsche and Commerzbank
were approached, but wanted to know the extent of any losses first. The
regulators called Iwan Herstatt, but he denied knowing anything about the huge
position, and anything about concealed losses. Herstatt then met with Dattel.
• Dattel himself did not know the exact amount of the concealed losses. On June
11, 1974, he told regulators that the losses totaled ($25 Million). On June 16, he
revised the figure to ($208 Million). A few days later, he revised the figure again
to ($480 Million). When notified of this, Deutsche Bank and Commerzbank
pulled out of a possible deal to buy Bankhaus Herstatt.
March 22, 2012 9
Rogue Traders and Risk Culture
Dany Dattel
• The regulators decided to close the bank. They chose a time in the afternoon
when West Germany was playing Yugoslavia in a World Cup soccer game,
thinking that most bank employees would not be at their desks, and that most
depositors would be temporarily distracted by the game.
• When the regulators closed the bank, Bankhaus
Herstatt had received the Mark legs of the foreign
currency transactions that were scheduled to
settle that day, but had not sent out the Dollar
legs that they owed.
• Twelve firms had sent Bankhaus Herstatt a total
of $620 million worth of Marks. These banks
were now de facto unsecured creditors of Confusion in Cologne as Bankhaus Herstatt is shuttered.
Bankhaus Herstatt.
• This caused mayhem in the world financial system. Rumors circulated that
some of the twelve banks were now insolvent. Their identities were not known,
so many banks stopped making payments to each other.
• Liquidity dried up, and the Clearing House Interbank Payments System
(CHIPS) stopped functioning for several days.
March 22, 2012 10
Rogue Traders and Risk Culture
Dany Dattel
• It was months before confidence in the world banking system was restored.
• Criminal prosecutions in the wake of the failure of Bankhaus Herstatt began in
1979. Ultimately, six employees of Bankhaus Herstatt (including three of
Dattel’s traders) were found guilty of various charges, and served between 2-7
years each in prison. Iwan Herstatt himself was found guilty of breach of trust,
and sentenced to 2 years probation.
• Interestingly, Dany Dattel was never tried. As Dattel’s legal troubles mounted,
he began to act erratically. His attorney told the presiding judge that Dattel was
showing signs of KZ Syndrome, a dangerous form of Post Traumatic Stress
Disorder that has a high suicide rate. Dattel’s KZ Syndrome was supposedly
related to the time he spent as a child in Auschwitz. The judge agreed. Citing a
Denazification law from 1946 that sought to reduce the number of prison
suicides, he decided not to prosecute Dattel.
• In the aftermath of the event, a whole new category of risk came into being,
called “Settlement Risk.” Settlement Risk (also known as “Herstatt Risk”) is the
risk that one party in a transaction will default after the other party has met
their obligations.
Dany Dattel
• It should be noted, however, that Bankhaus Herstatt did not fail because of
Settlement Risk. Regulators closed Bankhaus Herstatt because they had
insufficient capital relative to the size of their exposures.
• At the end of 1974, in response to the failure of Bankhaus Herstatt and the
ensuing chaos in the financial system, the G-10 countries formed the Basel
Committee on Banking Supervision, under the auspices of the Bank for
International Settlements (BIS).
• In 1988, the committee authored the Basel Capital Accord.
• Revised Capital Accords commonly known as “Basel II” and “Basel III” were
introduced in the subsequent decades.
2. The Rogues:
Nick Leeson
Nick Leeson
Nick Leeson
• The Singapore office had a shortage of traders, so Leeson asked the Home
Office if he could be a trader. They agreed to the move. He remained in charge
of the back-office while he traded.
• Leeson’s first trading assignment was as an arbitrageur covering the Nikkei
index. He monitored the price of Nikkei futures in the financial markets in
Singapore and Osaka. If he saw a large enough price difference in the two
markets, he was supposed to simultaneously buy the less expensive contracts,
and sell an equal number of the more expensive ones. The Market Risk was
minimal, because Barings would be long and short an equal number of Nikkei
futures. The difference in the purchase and sales prices represented the profit
or loss for Barings.
• Soon after he began trading, one of his back-office clerks made an error which
cost Barings $32,000. Leeson didn‘t want this person to get into trouble, so he
booked the loss to error account 88888, and suppressed the entry so that it
would not appear in management reports. This worked – Leeson’s superiors in
London did not find out about the error. Ominously for Barings, Leeson now
knew how to hide losses.
Nick Leeson
• Leeson started speculating in the futures markets. Like any trader, he had
good and bad days. But, because Leeson always reported his profits while
rarely reporting his losses, his reported P&L was much better than his actual
P&L.
• Leeson’s reported P&L impressed his colleagues and his superiors, and he
started to get a reputation as a top trader. However, by the end of 1992,
Leeson had hidden losses totaling ($3.6 Million) in account 88888.
• In 1993, Leeson' s reputation continued to grow. He was the subject of
newspaper and magazine articles, and was seen as one of the most dynamic
young traders in Singapore.
• Barings gave Leeson more and more autonomy to trade. The Singapore
office’s profit ostensibly increased by $14 million in 1993, due almost entirely to
Leeson' s seemingly profitable trading book. What they did not know, was that
Leeson’s actual trading results were terrible.
• As his losses mounted, Leeson had to ask London for cash to cover margin
calls. Leeson told his superiors that the underlying trades were for customers.
When asked for documentation, he faxed them deposit tickets that he had
forged. Management believed him, and honored his requests.
March 22, 2012 16
Rogue Traders and Risk Culture
Nick Leeson
• Desperate to recoup his losses, Leeson kept making bigger and bigger bets,
all the while hiding his losses in account 88888. By August 1994, the debit
balance in account 88888 was ($332 million). By the end of the 1994, the
balance was ($512 million). Barings was now on the precipice of financial ruin.
• At the end of 1994, Leeson’s deceptions were almost discovered by Coopers &
Lybrand, Barings’ external auditors. In order to cover some losses, Leeson
fabricated a $79 Million credit that had ostensibly been paid to Barings by
Spear Leeds. Coopers & Lybrand asked Leeson to contact Spear Leeds and
ask them to fax over a copy of the payment instructions. Leeson forged the
document and faxed it to the auditors. He was careful to change the “Fax
Number” field on the watermark of the fax so that it appeared to have been
sent from a fax machine at Spear Leeds. However, Leeson mistakenly did not
change the “Name” field on the watermark. Had the auditors looked more
closely at the fax, they would have noticed that it was not sent from “Spear
Leeds.” Rather, it was sent from “Nick and Lisa.” Meaning, it was sent from the
fax machine in the Leesons’ apartment.
• Coopers & Lybrand’s final report rated the controls in Barings’ Singapore office
to be “Satisfactory.”
Nick Leeson
• With the Nikkei at 19,000, Leeson became convinced that it would rise. So, he
bought 10,000 "straddles" on the Nikkei trading between 18,500 and 21,500.
Leeson’s trade was undone when, on January 17, 1995, a major earthquake
caused significant damage in Kobe, Japan. The Nikkei fell 7%, thereby making
the straddles unprofitable.
• Leeson then went all-in in what would prove to be the position that finally broke
Barings. He bought 20,000 futures contracts on the Nikkei @ $180,000 each,
for a nominal value of $3.6 Billion. Because of the immense size of the
position, if the markets moved sharply against him, Barings would not survive.
• At first, the trade was profitable. The Nikkei started climbing and by February
6, 1995, Leeson had made $200 Million on the contracts.
• But shortly thereafter, the Nikkei plummeted again. In the end, the losses on
this one trade totaled ($900 Million).
• Leeson was now often seen vomiting in the bathroom near the trading floor.
On February 23, at the end of the trading day, he left a note on top of his desk.
It said, "I'
m sorry."
Nick Leeson
3. The Rogues:
Toshihide Iguchi
Toshihide Iguchi
Toshihide Iguchi
Toshihide Iguchi
Toshihide Iguchi
Futures Trade:
• If Iguchi made money on a futures • Day’s Range = 100-110
contract, he would simply report it. • Purchase Price = 108
• End Price = 102
• However, if he lost money on a futures • Profit/Loss = -6 (102-108=-6)
----------------------------------------------
contract because it fell in price, he Basis Trade - Futures Side:
would do a basis trade with the dealer, • Value (set at Day’s High) = 110
and ask for the value to be set at the • Purchase Price = 108
• Profit/Loss = +2 (110-108=2)
day’s high.
Basis Trade - Bond Side:
• This is how the trades looked to Iguchi’s • Value (set at Day’s High) = 110
dealer: • End Price = 102
• Profit/Loss = -8 (102-110=-8)
-----------------------------------------------
Basis Trade - Net:
• Futures Side Profit/Loss = +2
• Bond Side Profit/Loss = -8
• Net Profit/Loss = -6 (2-8=-6)
• The Futures side of the basis trade was profitable, because the purchase price
was lower than the day’s high. The Bond side of the basis trade was
unprofitable, because the market price was lower than the day’s high price.
Note that the Net of the two basis trades is equal to the original value of
Iguchi’s futures trade. So, to the dealer, the machinations seemed legitimate.
March 22, 2012 24
Rogue Traders and Risk Culture
Toshihide Iguchi
Toshihide Iguchi
• The basis trades had another important benefit for Iguchi, in that they allowed
him to access Daiwa’s inventory of bonds anytime he needed to sell one to
raise funds to pay off a counterparty on a losing trade.
• Normally, Bankers Trust would not release a bond unless they received cash
for it. However, they would release a bond if they received a trade ticket
showing that the bond was used in an exchange for a futures contract as part
of a basis trade. Iguchi used these techniques year after year on thousands of
losing trades. Over time, his losses accumulated to historic proportions.
• Iguchi’s base salary was $40,000 a year. Another firm offered him a job with a
base salary of $150,000. However, Iguchi had to turn it down. By this time, he
had concealed hundreds of millions of dollars of losses, and knew that he
would go to jail if the frauds were discovered. As a result, Iguchi rarely missed
work.
• One day, a flood kept Iguchi from commuting to work. Fearing that his losses
would be discovered if his trades were settled by his coworkers, he called
brokers at other firms, and asked them not to settle his trades until he returned
to work. While this should have been a huge red flag to his coworkers, no one
at Daiwa wanted to directly challenge their star trader.
March 22, 2012 26
Rogue Traders and Risk Culture
Toshihide Iguchi
• Year after year, Iguchi continued the pattern of covering up his losses, while
reporting his gains. At one point, he was single-handedly responsible for over
50% of the NY office’s trading profits. But, it was all a fiction.
• Regulators sensed that something was amiss with Iguchi, so they paid special
attention to him. However, they were never able to catch him doing anything
illegal.
• In one infamous incident in 1992, the Fed sent a team of auditors to inspect
Daiwa’s trading desk. At Iguchi’s prompting, while the auditors’ attention was
focused elsewhere, Iguchi and the other traders left the building. Then, stacks
of cardboard boxes and office supplies were piled on top of the desks in the
trading room, and all of the computers, monitors, and lights were turned off.
When the auditors entered the room, they were told that it was just a storage
room. The auditors were skeptical, but moved on.
• Commenting on this incident and other close calls, Iguchi would later say, “I
was sometimes frightened by my own surprisingly strong nerves.”
Toshihide Iguchi
Toshihide Iguchi
• When Iguchi sent his letter to Daiwa, they were legally obligated to report the
fraud to the regulators immediately.
• However, Daiwa wanted to wait until after they reported their next Quarterly
numbers, so they didn‘t contact the Fed and the SEC until September 18,
which was two months later.
• The Fed and the SEC contacted the FBI, and Iguchi was arrested on
September 24.
• Iguchi cooperated with the investigators.
• When he was deposed, Iguchi told the judge that
after he had confessed to Daiwa senior
management, “…they asked me to continue
concealing the losses.”
• When asked about this, officials at Daiwa’s
headquarters in Osaka confirmed that this was true.
They justified it to the investigators by saying that
they did this “…in order to keep him from escaping.”
Iguchi on the cover of Time Magazine
Toshihide Iguchi
• In February 1996, Iguchi pled guilty to fraud and forgery. He was sentenced to
four years in prison.
• Daiwa pled guilty to 16 criminal charges, including falsifying books and records,
conspiracy, wire fraud, and obstructing a Fed examination. They were barred
permanently from doing business in the U.S.
• In the wake of the scandal, most of Daiwa’s senior management resigned,
including the Chairman, the President, and the Deputy President.
• While in prison, Iguchi wrote and published a book called “The Confession”
about his years at Daiwa, which became a best seller in Japan.
4. The Rogues:
Yasuo Hamanaka
Yasuo Hamanaka
Yasuo Hamanaka
Yasuo Hamanaka
Su copp
mb al
from producers in Zambia, who were in on
s
Za ysic
ian
m i er
the deception.
to m f r o
h
ck ells p
ob mG
• What the street didn’t know was
to
uy
e r mo s
(3) (1)
s p loba
that Sumitomo would then sell
ba
co mito
hy l
sic
the physical copper they had
Su
pp
l a
purchased from Global back to
(2)
the Zambians, thus completing a
Global buys warrants redeemable in
triangle of transactions. Zambians physical copper from Zambians Global
Yasuo Hamanaka
• Sumitomo opened cash and trading accounts with Merrill Lynch. Using
Sumitomo’s financial clout, Hamanaka was able to establish $600 Million in
credit facilities with Merrill Lynch and several other A-list banks.
• Hamanaka also opened a “B” account at Merrill Lynch for Global. With Merrill
Lynch’s consent, Global was allowed to utilize the credit lines that Merrill Lynch
had approved for Sumitomo. Global was given power-of-attorney, and could
theoretically trade any way they saw fit. Of course, neither Merrill Lynch nor any
of Sumitomo’s other creditors were aware of the true nature of the relationship
between Sumitomo and Global.
• With all of the angles worked out, Hamanaka went live with his strategy.
• By September 1995, Sumitomo owned warrants on 50% of the physical copper
that was traded on the LME. By November 1995, that figure increased to 90%.
He also owned by far the biggest futures position in the world. The copper
market was now cornered.
• For several years, the strategy was seemed to be profitable for Sumitomo.
However, all the while, Hamanaka was hiding a mountain of losses.
Yasuo Hamanaka
Yasuo Hamanaka
• In the end, an errant piece of mail led to Hamanaka’s downfall. When he traded
on the LME, he arranged for the paperwork to be sent directly to himself.
However, the paperwork for one of his unauthorized trades was inadvertently
sent to Sumitomo’s Finance department. At around the same time, a clerk at
Sumitomo discovered unauthorized accounts at Merrill Lynch, and reported
them to senior management. Sumitomo started an investigation.
• On May 9, 1996, Sumitomo demoted Hamanaka from his role as Head Copper
Trader. On June 5, 1996, Hamanaka confessed what he had done, and gave
management his secret trading book.
• On June 14, 1996, Sumitomo’s president told shareholders about ($1.8 Billion)
in previously undisclosed losses that were incurred by Hamanaka.
• To reduce their exposures, Sumitomo had to sell off much of the inventory that
Hamanaka had accumulated. There were few buyers, causing prices to drop
sharply. Sumitomo lost an additional ($800 Million) selling off Hamanaka’s
excess copper inventory, bringing the total losses associated with Hamanaka’s
unauthorized activities to ($2.6 Billion).
• Yasuo Hamanaka was arrested and tried. He pled guilty to the charges, and
was sentenced to eight years in prison.
March 22, 2012 37
Rogue Traders and Risk Culture
5. The Rogues:
John Rusnak
John Rusnak
John Rusnak
• Rusnak’s downfall began in 1997, when he incurred large losses betting that the
Yen would strengthen versus the Dollar. Afraid of the fallout, he entered fictitious
options trades on Allfirst’s systems that made it appear that his losing trades
were hedged, and forged trade confirms.
• Emboldened by his success in covering up the loss, Rusnak doubled down on
the Yen to try to get even. Once again, his trades lost money.
• He continued trading and losing money, then concealing the losses by entering
winning trades on the system. This pattern continued for months, until Rusnak
had lost millions, and then tens of millions, and ultimately hundreds of millions of
Dollars.
• Rusnak’s Value at Risk (VaR) limit was supposed to be $2.5 Million for any
single currency position. Allfirst’s VaR model estimated potential losses by
generating 1,000 hypothetical F/X spot trades for a trader’s portfolio, and then
calculating the resulting Profit or Loss. The VaR of a position was equivalent to
the tenth-worst outcome produced by the simulation.
• Allfirst’s model had a major flaw - the underlying data was taken from the traders
own spreadsheets, not from independent sources.
John Rusnak
• Rusnak knew how his VaR was calculated, so he altered his spreadsheets to
exploit this flaw. At the height of his activity, Rusnak had over $1 Billion in
unhedged Yen positions versus the Dollar. Yet, he was never flagged for a limit
violation.
• His losses were staggering. From 1997-1999, Rusnak concealed ($130 million)
in losses. In 2000, he concealed another ($211 million). And in 2001, he
concealed another ($270 million).
• As the losses grew, so did the size of the offsetting fake trades. The fake trades
were so large and so profitable for Allfirst that Rusnak thought that it was only a
matter of time until his activities were discovered.
• Rusnak wasn’t exactly a master criminal. In 2001, an
external auditor wanted to confirm a (fake) trade. When
Rusnak was asked for the counterparty’s contact info, he
told them “2472 Broadway in Manhattan.” This was
actually a Mailboxes Etc. storefront, where Rusnak rented
a box under the name “David Russell.” A few days later,
Rusnak went to the store, retrieved the letter, forged the 2472 Broadway circa 2001
John Rusnak
• Rusnak started using “historic rate rollovers” to defer reporting his losses.
• Historic rate rollovers allow existing currency positions to be rolled forward using
historic rates instead of current market rates.
• Allfirst’s Internal Auditors saw that Rusnak was using historic rate rollovers in
epic amounts, but didn’t really question him about it.
• However, historic rate rollovers use the Balance Sheet.
• In short order, Rusnak’s was single-handedly using 10% of Allfirst’s Balance
Sheet. Allfirst’s Treasurer ordered him to stop using the rollovers.
• Rusnak still needed vast amounts of money to meet margin calls and pay for his
losses. But, he couldn’t ask anyone for it directly, so he had to come up with
another way to get his hands on some cash.
John Rusnak
• In February 2001, Rusnak started selling “deep in the money options.” With
deep in the money options, the strike price of the option in the future is
extremely low relative to the current market price in the case of a Call, and
extremely high in the case of a Put. This means that buyers of deep in the
money options are very likely to make large profits. For the seller, the main
benefit of deep in the money options is instant liquidity - they receive money
immediately, in exchange for a high likelihood of having to pay a lot more
money at the exercise date, which is in the future.
• Rusnak raised $300 Million by selling deep in the money options to Citibank,
Deutsche, Bank of America, and Bank of New York. The exercise dates
weren' t until February 2002, so Rusnak was able to continue his unauthorized
trading for another year. But, he was still not able to recoup his losses.
• When the deep in the money options came due, Rusnak had to pay the four
banks ($380 Million), an ($80 Million) premium over the sale price of the
options. This additional loss of ($80 Million) brought Rusnak’s total losses to
($691 Million). Rusnak was finally literally and figuratively out of options.
John Rusnak
6. The Rogues:
Jérôme Kerviel
Jérôme Kerviel
Jérôme Kerviel
Jérôme Kerviel
• From January 2-18, 2008, Kerviel built up a new long position on index futures,
reaching a stratospheric $72 Billion. This far exceeded Société Générale’s
Market Cap, and was not hedged.
• The position was discovered on January 20, 2008. The size of the position put
Société Générale at risk, so it was decided to unwind it. The position was
unwound from January 21-23, incurring losses of ($8.9 Billion).
• Taking into account Kerviel’s trading profits of $2.2 Billion in 2007 and trading
losses of ($8.9 Billion) in 2008, the net result of Kerviel’s unauthorized trading
was a monumental loss of ($6.7 Billion). This amount exceeded the combined
rogue trading losses incurred by Yasuo Hamanaka ($2.6 Billion), Nick Leeson
($1.3 Billion), Toshihide Iguchi ($1.1 Billion), John Rusnak ($691 Million), and
Dany Dattel ($480 Million).
• On January 24, 2008, Société Générale announced that they had lost
($6.7 Billion) due to “exceptional fraudulent trading activities.” After the
announcement, their stock plummeted, knocking ($18 Billion) off their market
cap.
Jérôme Kerviel
• On January 26, 2008, Kerviel was taken into police custody. He was formally
charged with “Abuse of Confidence” and “Illegal access to Computers,” and
then released.
• As details of the case started to become public, Société Générale engaged in
an ill-advised war of words with Kerviel. CEO Daniel Bouton described his
unauthorized activities as a “mutant virus,” and called Kerviel “a terrorist.”
Kerviel fired back, saying that management was aware of his activities, but
turned a blind eye as long as they thought he was making a profit.
• Many people in France became sympathetic towards
Kerviel. They thought of him as an anti-hero who was
just doing what his bosses wanted him to do, only to
be made a fall guy when markets turned against him.
• Around Paris, some people could be seen wearing
shirts that were openly supportive of him, saying
things like “I am Jérôme Kerviel’s Girlfriend” and
“When I grow up I want to be like Jérôme Kerviel.”
Pro-Kerviel T-shirt
Jérôme Kerviel
Jérôme Kerviel
Jérôme Kerviel
Jérôme Kerviel
Jérôme Kerviel
7. The Rogues:
Kweku Adoboli
Kweku Adoboli
London office.
• Because the legal proceedings associated with the event are currently
ongoing, UBS has decided not to provide their own comprehensive analysis
yet.
March 22, 2012 56
Rogue Traders and Risk Culture
Kweku Adoboli
Kweku Adoboli
Kweku Adoboli
• Anonymous UBS sources told Reuters that Controllers had been focused on
Adoboli since July 2011. They suspected that he was using fake offsetting
trades with other parts of the bank to make it seem as if his long positions were
hedged, and keep within his trading limits. These “internal futures” at UBS do
not require confirmations.
• When Adoboli became aware of the attention he was receiving from
Controllers, he allegedly switched to using forward settling trades that used
Exchange Traded Funds (ETFs).
• Many of these trades had Settlement Dates two months after the Trade Dates.
This bought Adoboli time to continue to manipulate UBS’s systems. As the
Settlement Dates of the trades approached, Adoboli would allegedly cancel
those trades, and replace them with new trades that also had Settlement Dates
far in the future.
• Since his arrest, Adoboli has been largely silent, although his lawyer said that
Adoboli was “sorry beyond words.”
• Kweku Adoboli’s trial is scheduled to begin in London in September 2012.
Two Who Didn’t Make the List: Bad Traders, not Rogue Traders
• Brian Hunter
Hunter was a star energy trader with Amaranth Advisors. In 2005, he was
given a bonus of $75 Million for trading profits of almost $1 Billion. In 2006,
with the approval of Amaranth’s senior management, he bet almost the entire
capital base of Amaranth on an unhedged natural gas futures position.
Ultimately, the position lost ($6.5 Billion), putting Amaranth out of business.
Hunter is frequently called a “Rogue Trader.” However, this is inaccurate,
because his trades were done with the knowledge of his management. It is
more accurate to call Hunter a “bad” trader than a “Rogue Trader.” As of 2012,
he continues to trade.
• Boaz Weinstein
Weinstein was a star derivatives trader with Deutsche. From 2006-2007, his
team made a profit of $1.5 Billion, and Weinstein was reportedly paid more
than Deutsche’s CEO. However, in a calamitous 2008, his prop trading team
lost ($1.8 Billion). Weinstein left Deutsche in 2009 to start his own hedge fund.
Weinstein is also sometimes called a “Rogue Trader.” This is inaccurate, as his
trades were done with the knowledge of his superiors. Like Hunter, it is more
accurate to call Weinstein a “bad” trader than a “Rogue Trader.”
March 22, 2012 60
Rogue Traders and Risk Culture
Product/Desk F/X Derivatives Fixed Income Commodities F/X Delta One Delta One Treasury
Location Home Office Branch Office Branch Office Home Office Branch Office Home Office Branch Office Home Office
• The diversity of results on the Heat Map clearly illustrates that Rogue Traders
do not fit neatly into one well defined profile.
March 22, 2012 61
Rogue Traders and Risk Culture
Potential for
Capability Employee Fraud Motivation
Rationalization
Potential for
Employee Fraud
Potential for
Employee Fraud Motivation
Potential for
Employee Fraud
Rationalization
• Someone with the Capability to commit a fraud has the intelligence and
wherewithal to recognize and exploit internal control weaknesses. That person
also needs to have the self-confidence to believe that they can pull off a fraud
without getting caught.
Potential for
Capability Employee Fraud
William Pullinger
Introduction
Introduction
• His rogue trades were successful at first. He withdrew his profits from the
bank, and bought real estate, racehorses, and other trappings of wealth.
• Inevitably, he started losing money. He paid for losses by withdrawing funds
from UBL’s account with the Bank of England. He increased his bets to try to
recoup his losses. Unsuccessful, he bet progressively larger amounts to try to
get even. His losses mounted. Over time, his losses trading in British financial
markets totaled ($75 Million*).
• Through an intermediary, Pullinger started trading huge amounts of money in
foreign financial markets. However, lost even more money. Pullinger ultimately
lost ($185 Million)* in markets outside of Britain, including ($50 Million*) in
Mexico, and ($20 Million*) in Turkey. All told, after five years of rogue trading,
his losses totaled ($260 Million*).
• A funeral obliged him to be away from the office for several days. His
unauthorized activities were discovered, and he was arrested. Pullinger pled
guilty, and was sentenced to 20 years in prison in Australia. He died on a penal
ship while in transit to Australia.
• Depositors ran on UBL. The Bank of England announced they would backstop
UBL. This calmed down depositors, ending the crisis.
March 22, 2012 70
Rogue Traders and Risk Culture
Introduction
1860
Contact Information
Neil Roth
BNP Paribas
Oversight of Operational Permanent Control
51 West 52nd Street – 36th Floor
New York, NY 10019
Phone: 212-471-6374
Cell: 914-214-1152
Email: neil.roth@us.bnpparibas.com
Disclaimer
This document has been prepared by BNP PARIBAS for informational purposes only. Although the information in this document has been obtained from sources which BNP
PARIBAS believes to be reliable, we do not represent or warrant its accuracy, and such information may be incomplete or condensed. This document does not constitute a
prospectus or solicitation and is not intended to be and must not be the sole basis for any evaluation of the securities discussed herein. All estimates and opinions included in
this document constitute our judgment as of the date of the document and may be subject to change without notice. Changes to assumptions may have a material impact on
any recommendations made herein.
BNP PARIBAS or its affiliates may, from time to time, have a position or make a market in the securities mentioned in this document, or in derivative instruments based
thereon, may solicit, perform or have performed investment banking, underwriting or other services (including acting as adviser, manager or lender) for any company,
institution or person referred to in this document and may, to the extent permitted by law, have used the information herein contained, or the research or analysis upon which
it is based, before its publication. BNP PARIBAS or its affiliates will not be responsible for the consequences of reliance upon any opinion or statement contained herein or for
any omission.
This document is confidential and is being submitted to selected recipients only. It may not be reproduced (in whole or in part) to any other person without the prior written
permission of BNP PARIBAS. Any U.S. person receiving this presentation and wishing to effect a transaction in any security discussed herein, must do so through a U.S.
registered broker dealer. BNP PARIBAS Securities Corp., a subsidiary of BNP Paribas Financial Services, is a member of the NASD and SIPC, and a U.S. registered broker-
dealer with the U.S. Securities and Exchange Commission.
End of Presentation