Specifically, JBI fabricated a finder’s arrangement between BJB and Dimitri Merinson, an employee of several Yukos Group companies. Merinson received a finder’s fee from BJB for introducing Yukos Group to Julius Baer. The understanding between the two companies was that the Yukos Group would place a large amount of cash with Julius Baer, thus pushing the revenue of the bank higher.
The FCA further highlighted that Merinson and Julius Baer shared profits from uncommercial FX transactions. In fact, Merinson received about $3 million from these illegal arrangements.
Additionally, JBI did not have adequate policies and procedures for identifying and managing the risks from relationships between JBI and finders, which brings potential clients. Though the bank introduced some policies after June 2010, they were inadequate.
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