Case
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 CEO Pierre Cremieux; Managing Principals Michael Holland, Richard Starfield, and Samuel Weglein; Principals Brian Ellman and Chris Feige; Vice President Hadrien Vasdeboncoeur; and Manager 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.
Meet Our People
Chris Feige
PrincipalMr. Feige specializes in the areas of finance, securities, and financial markets. He has worked on and managed a range of securities and valuation projects in the UK and Europe. Mr. Feige has been appointed as expert in Dutch court to provide valuation and securities claims reports in support of Steinhoff’s global securities settlement, and gave evidence in the Dutch Enterprise Chamber regarding the valuation of Getir. He has also managed teams evaluating shareholder reliance and disclosure materiality and estimating counterfactual share prices in UK Financial Services and Markets Act (FSMA) Section 90A litigation matters. Mr. Feige has supported experts analyzing the volume of false and spam accounts on Twitter, Twitter’s information security infrastructure, Twitter’s data privacy and compliance with a US Federal Trade Commission (FTC) consent decree, and share price and valuation issues on behalf of Twitter in Twitter v. Musk in which Elon Musk eventually purchased Twitter at his initial offer price. In cases involving alleged market manipulation in the foreign exchange (FX) and IBOR markets, he has analyzed trade data and evaluated alleged manipulation strategies. Mr. Feige worked on USA v. Richard Usher, et al., and the Foreign Exchange Class Antitrust Litigation, analyzing FX trade and chat data, as well as competition issues; preparing experts for testimony at trial; and providing data analyses and consulting support to counsel throughout the projects. He has also worked on a range of international arbitration cases, including valuation, damages, and competition analyses. In addition, he has developed complex valuation models, including discounted cash flow models, and analyzed asset-backed securities, collateralized debt obligations, and other securitized products in support of expert testimony in a number of bankruptcy and damages matters. Mr. Feige has also worked on a number of international arbitrations valuing defaulted sovereign debt, expropriated oil fields, and retail operations. His work has been published in several industry journals.