Fed Fines Goldman $110mn FX

On May 1, Fed, DFS fined Goldman Sachs $110mn in FX trading.

  • Goldman Sachs charged for unsafe, unsound practices, in FX trading business.
  • Traders buy and sell currencies for the firm's own accounts and for customers.
  • Dealing done through indirect subsidiaries, both in US and in overseas offices.

Alleged Violations

  • Firm did not detect traders' use of chatroom to communicate with competitors.
  • Traders discussed respective positions, fixes to benchmark, to increase profits.
  • Firm failed to detect disclosures of client information by traders to other firms.


  • Feed expect strong governance of compliance risk at all levels of management.
  • Policies and procedures, rigorous surveillance, escalation mechanisms, training.


  • Both the Fed and NY DFS each fined Goldman $54.75mn for total of $109.5mn.
  • Orders required firm to improve controls over FX compliance risk management.
  • Policies for types of communications staff may use to communicate with others.
  • Types of trade and confidential customer information that may be so disclosed.
  • Conduct for responding to conflicts with customers that place execution orders.
  • Compliance reporting for staff to report violations of policies, US law and rules.
  • Training for staff in market activity, on policies and laws for job responsibilities.