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On December 7, 2011, Cairn Energy trusted HSBC with a $3.5 billion currency conversion, and a promise that it would be handled quietly. Instead, HSBC's FX desk set a ceiling of 1.5730 in advance, exactly 100 pips above the rate when the order came in. They ramped sterling into the 3 p.m. WM/Reuters fix, and when Cairn asked about the spike, they blamed the Russian Central Bank.
In this episode we rebuild the trade minute by minute from the court record: the recorded calls, the 2:54 p.m. instruction six minutes before the fix window, the $7–8 million profit, and HSBC's $101.5 million settlement. Then comes the twist. Mark Johnson was convicted, served his sentence, and saw his conviction vacated in 2025, after a Supreme Court ruling threw out the legal theory used to convict him. The trading facts were never disproven.
For surveillance analysts, we cover what would flag this today: a pre-calculated target price, calls followed by correlated trading, abnormal price action inside the fix window, and a client explanation that didn't match the order book.
Sources: United States v. Johnson, 945 F.3d 606 (2d Cir. 2019); Johnson v. United States, No. 24-1221 (2d Cir. 2025); DOJ Information, United States v. HSBC Holdings plc, No. 18-cr-00030 (EDNY).
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