FCA fines Dinosaur Merchant Bank Limited for market abuse surveillance failures

The FCA has fined Dinosaur Merchant Bank Limited (DMBL) £338,000 for failing to put in place effective systems and controls to detect and report suspicious trading in its contracts for difference (CFD) business.

CFDs are sophisticated financial products that are used to speculate on various assets going up or down in value. Given their high-risk nature, firms must have strong and reliable surveillance arrangements to prevent insider dealing and market manipulation. 

In June 2024, DMBL introduced a new order system that led to a sharp increase in CFD trading by its clients. Between June and October 2024, trades with a corresponding asset value of approximately $3.05 billion were executed via the platform. However, these orders and trades were not captured and reviewed by the automated surveillance system which meant that potential market abuse could have gone undetected.

Although DMBL identified this issue in October 2024, the firm failed to properly address the deficiencies until May 2025. The delay limited the firm’s ability to identify and report potentially suspicious trading.

Steve Smart, joint executive director of enforcement and market oversight, said:

‘DMBL’s failures had the potential to undermine the integrity of the market. Firms must ensure they have effective surveillance arrangements in place. We will continue to take action where this is not the case.’

DMBL fully cooperated with the FCA investigation and qualified for a 30% discount. Without this discount, the fine would have been £482,900. The firm stopped selling CFDs in May 2025. This case, taking just 9 months from opening to achieving a public outcome, demonstrates the FCA’s continued work to improve the pace of its enforcement investigations.

Notes to editors

1. Final Notice: Dinosaur Merchant Bank Limited (PDF).

2. DMBL breached Article 16(2) of the UK Market Abuse Regulations (UK MAR), SYSC 6.1.1R of the Senior Management Arrangements, Systems and Controls chapter of the FCA’s Handbook and Principle 3 of the FCA’s Principles for Businesses.

3. Market abuse surveillance systems serve to protect the integrity of financial markets, foster investor confidence and ensure fair trading by detecting, preventing and reporting illegal activities like insider dealing and market manipulation. They enable firms to comply with regulations (eg, UK MAR and the Market Abuse Directive on Criminal Sanctions) by analysing trade data for suspicious behaviour, such as spoofing or front-running, to identify misconduct at an early stage.

4. For further information on market abuse surveillance, read the FCA’s newsletter on market abuse surveillance and market abuse peer review into firms that offer CFDs.

5. Find out more about the FCA.