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UNITED STATES OF AMERICA
BEFORE THE BOARD OF GOVERNORS

OF THE FEDERAL

WASHINGTON,

RESERVE SYSTEM

D.C.

__________-----_______________-x

DOCKET NO. 98-032-B-1
98-032-CMP-I

In the Matter of
GUILLAUME HENRI ANDRE
FONKENELL
An Institution-AfHiated
Party of
BANKERS TRUST COMPANY
New York, New York

Notice oyCharges
and of Hearing and Notice
of the Assessment of a Civil
Money Penalty Issued
Pursuant to Sections 8(b)
and (i) of the Federal Deposit
Insurance Act, as Amended

_______________________________y

The Board of Governors of the Federal Reserve System (the “Board of
Governors”)

is of the opinion and has reasonable cause to believe that
(A)

Guillaurne Henri Andre Fonkenell (“Fonkenell”), a former Vice President

of Bankers Trust Company, a state member bank ifor purposes of this Notice. Bankers Trust Sie\~,
York Corporation

and its subsidiaries. including Bankers Trust Company collectively will be

referred to as “BT”), knowingly and recklessi! breached his fiduclap
violations of law and unsafe-and-unsound
sale of leveraged derivatives transactions

duties and engaged in

bankIng practices in connection
( “LDTs” )

with the marketing and

Fonkenell also knowingly and recklessly

breached his fiduciary duties, and engaged in vloiations of law and unsafe-and-unsound

banking

practices with respect to entries he caused to be made in BT’s books and records
(B)

Fonkenell conspired to and did engage in a scheme to defraud in

connection with the sale and marketing of LDTs to the Indonesian companies. P T Adimitra

Rayapratama

(“Adimitra”j and P.T. Dharmala Sakti Sejahtera (“Dharmala”).

This scheme

included the following conduct:
(I) Fonkenell and others conspired to and did engage in a fraudulent
scheme to induce Adimitra and Dharmala to enter into certain LDTs by misrepresenting
material risks of those transactions.

the

who was a marketer, requested
L’
that Fonkenell, a trader, alter the format of an LDT structure so as to hide the leverage in the
transaction Corn prospective
newly formatted

clients.

A colleague of Fonkenell’s,

Fonkenell did after the appearance of the LDT, and the

structure was presented to Dharmala and Adimitra in proposal letters sent by the

marketer; and
(II) The reformatted
presentations
components

to Adimitra and Dharmala.

formula created by Fonkenell was used in marketing
In those presentations,

of the LDT structure was misrepresented

the function of certain

SC as to conceal the leverage in the LDT

from Adimitra and Dharmaia
Fonkenell, with the assistance of others, manipulated BT’s books and

(0

records so as to misstate materially the amount of trade date profit generated with respect to
another transaction he executed
By reason of the practices set forth in Paragraphs B and C above,

(D1

Fonkenell received pecuniary gain or other benefit, and BT suffered more than minimal loss, as set
forth below:

6
‘\

(11

Fonkenell conspired to and did fraudulently induce Adimitra and

i

Dharmala to enter into LDTs for the ultimate purpose of generating high revenue for BT so that

2

he could be awarded a substantial bonus.

In 1994, Adimitra and Dharmala collectively suffered

losses in excess of one hundred million dollars, a portion of which was ultimately absorbed by BT
(II)
BT’s management

Fonkenell manipulated

BT’s books and records in order to present

with a more favorable impression of his abilities as a trader, for the ultimate

purpose of increasing his bonus.

These actions adversely affected, or had the potential to

adversely affect BT’s risk management
Accordingly,

operations.

L’

the Board of Governors herebi institutes this proceeding

issuing this combined Notice of Charges and of Hearing

by

and Notice of Assessment of a Civil

Money Penalty (the “Notice”) for the purpose of
(I)

assessing a civil money penalty against Fonkenell pursuant to

Section S(i) of the Federal Deposit Insurance Act, as amended (“FDI Act”), 12 U S C $ 18 IS(i ).
(II)

determining whether an appropriate order should be issued,

pursuant to Section 8(b) of the FDI Act, 12 U S C 5 1818(b), requiring Fonkenell

to

permanently cease and desist from serving in any capacity as an institution-affiliated

party of an

institution or agency specified In SectIon 8(e)(7)(A) of the FDI Xct ( 12 I-’S C $ IS 1S(e)i7)(.4i 1,
including a bank, bank holding cornpan!‘, or nonbank subsidiar),, lvithout Federal Reserve
approval, and serving as an Institution-affiliated

party of any institution or agency specified in

section S(e) (7) (A) of the FDI &zt. ( 12 U S C $ 1818 (e) (7) (A)), including a bank, bank
holding company, or nonb,ank subsidiary, where his duties include, directly or indirectly
(a) participating I? the structuring of derivative transactions for marketing or sale to customers,

(b) advising any customer regarding the purchase, sale or structuring

of a derivative transaction,

(c) preparing marketing materials regarding derivativ,e transactions
In support of this Notice, the Board of Governors alleges the following
.JURISDICTION
1
1994

Fonkenell was employed by Bankers Trust Company from 1990 through

During the time he was employed by BT, Fonkenell worked %,a trader based in New

York. As a trader, Fonkenell was responsible for managing trading positions held by BT as well
as structuring transactions
coordinating

to be marketed to BT’s clients

Fonkenell was also responsible for

with employees in BT’s operations area to ensure that the value of transactions he

executed were appropriately

recorded in the books and records of the bank

1994, Fonkenell was an opttons trader on BT’s dollar dertvativ,e desk
L’ise

From 199 I through

Fonkenell held the tltlc ot

Prestdent when he resigned fri>nl PIi‘III \la> i W-l
?

Fonkenell \v,~s at all trmes pert~r,en: hereto an institutton-afliliated

Bankers Trust Company, as detined for the purpo‘;es (Tfthis Notice b\, Section 3(u)
.\ct. 12 I. S C $ 1S13(u)

-I< AI)!n,titliri~~n-rittiIldtec! ?xt\

IS subtect to the cease-and-desist

v i ;I\ pi m~nt’~ perxltv
.L~~

pan’ ,,:‘

ofthe i-D1

oi Banhers Trust Cornpan\. F~~IIK;.;::::!
assessment prc>\Istons of the I-111 A;;

12 L’S C +$ ISIS(b) and(i)
3

(a) The Board I)r‘C;o~ernors 1s the approprtate

Federal bankins arehi\

take actton against an instltutlon-~~ttil~ateci pan\’ of a state member insured bank pursuant ;(I
Section 3(q) ofthe FDI Act. 12 I s C 9 lSl.:~q~

:i’

The Board of Governors

lb)

has jurisdiction

over Fonkenell for

purposes of this proceeding.
FACTUAL
1.

ALLEGATIONS

Background
4

Fo&enelI was, at all times relevant to this Notice, an options trader on the

dollar derivative desk of Bankers Trust Company.
5.

‘r’

A derivative is a financial product, the value of which is based on another

financial instrument or index, often an interest rate, foreign exchange rate, or the yield on
a security

derliatlve

with

A.

Leveraged Derivative Transactions

6

A

either
7

For example.
Leverage

financms

explicit

or Implicit

an in\,estment

the financial

The pa\‘ments

9
One method
extending

There

the maturity

ofthe

the le\.erase

movements

that c,lpture

components

0~ er the Ilfe of the transaction

to a \,arlable

transaction

m the LDT’s

has the effect

ofan

transactlon
expressed

In the form

of the LDT

and

and at maturlt>

ie\,erase

to a derl\,arlve

formula

For certain

ofincreasIng

in\sestment

ofthe In\‘estmenr

are generally

the tinanclal

means ofaddins

return

on d derlLat[ve

nssoclClted Lvlth an LDT

are numerous

is to add a multiplier

both the risk and the potential

~~t’;llarkt’t

formulae

arrangements

components

bvith debt increases

the Impact

or more mathematical

describe

le~eraye

LeL.erage Increases

tends to Increase
s

of one

leveraged derivative transaction (“L.DT”J is generally considered to be n

the leverage

transactlon
structures.

10

Beginning in 1992, and accelerating

marketed LDTs to its corporate

customers

through

1993 and 1994, BT sold and

as a means of hedging exposure and also as a way to

take positions on one or more markets such as interest rates or foreign exchange
11
transactions

While many of BT’j customers wanted to enter into highly leveraged

in order to take advantage of the higher potential returns, others wished to avoid the

high risk inherent in such trades.
12.

‘d’

Fonkeneli was expected to develop

and in response to requests or suggestions
13
derivatives.

new ideas

from marketers.

Marketers were responsible for working with traders to develop and price

They were expected to be able to understand a customer’s objectives and to have

sufficient technical knowledge
14

of LDTs to express those objectives to traders

In the conteyt of Bl“.;, derlv atrve busrness, highly leveraged transactrolls

were generallv more profitable than unle\ eraged transactions
encouraged

for trades, both on his own

to create new dertv,ati\,e structures Incorporating

Traders were according]!,
high degrees of leverage

The

extent to which a trader succeeded In de\elop~n~ trades that iic’re profitable to BJ RX a
significant factor used bv BT‘i rnana~ernerlt to determine a trader’s bonus

Fonkeneil \\.as di+‘~r~

of this correlation
I’

Ever-v derlv,atlve sold h> BT to one of

its

customers was an arms-length

transaction

BT did not typtcallv undertake an! ilduclarv obligartons towards its sophrsucated

counterparty

derivative customers

%onetheless. Fonkenell took affirmative steps to mtsrepresent

to BT’s customers the material risks of ct’rtaln transactions

I

B.

Books and Records of the Bank

16

In addition to developing

new trades, Fonkenell was also responsibie for

managing the trading positions contained on the options book to which he was assigned.
Fonkenell’s responsibilities

One of

in managing the options book was to ensure that transactions were

valued consistently with market parameters
17

One parameter that materially affects the valuc,of all options is volatility.

Volatility is a measure of the degree of uncertainty of future price qovements.
responsible for ensuring that all options transactions

Fonkeneil was

on BT’s books and records were valued

using accurate volatilities.
18

During 1993, a liquid market in volatilities was in existence.

any given time, the market for a particular volatility varied within a trading range
Fonkenell was permitted and expected to exercise his professlnnal judgment

However, at
Therefore,

in determining the

appropriate L,olatilitles to be entered on BT‘s books and records
19

“Yew deal” profit was used b!, RT‘s management

the antlclpated protit on a newly hooked transactlon
allocations given to marketers

as an approximation

ot‘

It \\as also used as the basis for the profit

These protit allocatlons \iere used as a benchmark to determine

the profits generated by an indi\,ldual marketer
20

A factor in determIning a trader’s compensation

that trader participated in generating for BT

was the amount

of profits

In this regard. a trader would be given credit for

ne\\ deal profit generated by a transaction that he or she helped to structure
atso he given credit for profit generated as a result It‘managlny

He or she would

positions in his or her trading

book

On the other

trader

was unable

transaction

hand, a trader‘s

compensation

to manage his or her trading

throughout

would

book

by the perception

so as to maintain

Fonkenell

the life of the trade

be affected

was aware

the expected

of the factors

that the

profit

affecting

of a
his

compensation

Alteration of the Libor Barrier Swap So As to Hide the Leverape in the
Transaction

II.

21

On or about January

message to be sent to a marketer
in Malaysia,

Singapore

a new trade,

known

who sold and marketed

and Indonesia

as a “Libor

18, 1994, Fonkenell

(the “January

barrier

cau%d

derivatives

18 E-Mail”)

swap,” to be presented

an electronic

to BT’s

mail

corporate

The subject

customers

of the message was

to that marketer‘s

Indonesian

customers
7-l
--

option

component

The I.ibor
.At maturltv.

17
-3
payment.

L’nder

BT and the customer

ofthe

and thus the amc,unt the ;u~tomc’r
barrier

Januan

~~3s -I ‘<O ‘I

1S E-Lla~l
2-l

during

swap v.‘as a t>‘pe of swap transaction

the terms

crossed a specified

of an

harrier

express

rtiultipllcr

dtlrlnc

Libor

in the 5prt’di-i t;~rmula

increase

expressed

L_tbor

as the multiplier

18 E-hIail

9r1

rate payments
interest

b\ a “spredd”

The barrier

Libor

the spread would

I il * (h-month
IS

in the Januar)i
If6-month

Interest

slvap. the customer’s

oL{ed BT. ivould

The prcoposal contaIned

the le\eraye

barrier

exchange

rile tirsr \ ear of the transactIon

the first year oi the transactlon,

In this formula.

would

that Included

rate

~f[.~bor

Fpeslfied

Leas le\,eraged

in the’

bv \‘lrtue

?\ere to trade above 4 ‘!“,I

be equal to
-

-3 759

0)

” IO” at the beylnnlng

cut’
the formula

I

25

Mer

receiving the January I8 E-Mail,

marketer to whom it was sent

the

requested that Fonkenell alter the spread formula in the January 18 E-Mail so as to “hide the
leverage” in the formula.
26
telephone

with

On or about January 19, 1994. Fonkenell

a colleague

based in Tokyo

discussed

the proposal

Fonkenell stated that it was

In that conversation.

He and his c$league

“easy to hide the leverage” in the proposed transaction

over the

discussed possible

means of hiding the leverage, but were unable to agree on a method,of doing so.
27.

Fonkenell stated that he would

work

on the problem.

He and his colleague

agreed that they would discuss the proposal again later
28.
regarding

the proposal

On or about January 24, Fonkenell again spoke with his colleague
contained

had “\+ranted to send something

in the Januarv

18 E-Flail

to [the marketer]

:&>ut.

trade,” but had not had time to finish
29
been shown
component

Fonkenell

on hiding

the leverage,
;o

sent to the marketer

‘Oh. i>ka\

Fonkenell‘s
statrng,

Fonkenell
referenced

eyplarned

hiding

rhat the Libor

presumabl~~ In its iTrl<rnal term.

then asked.
now””

J~CM_I
kno\\.

told his colleague
the leverage

Tokyo

that he
on th1.s

~$ork~ng or1 I:

collea~+e

to se\,eral customers,

it’s okay as it is right
work

Fonkenell‘s

Fonkenell

in

“it‘s

trade had alread!

Lvrth an espiicit

leverage

Do \ct’ need to find a stay ICI hrde the IeL~era~e. i)r

solleague

responded

for another

caused an eiectronrc
in paragraph

barrier

WV
_ :

that Fonkeneil

Lve will

should

tc’

still need to hide the le\,eraoe
_’

marl message. dated January

‘3 I abo\,e t the “Januam

contrnue

23 E-%LZail”)

23. 1994.
Upon

to be

information and belief, although the message was dated January 23, Fonkenell caused the message
to be sent some time after the conversation

with his colleague on January 24

The January 23 E-Mail stated in part that Fonkenell had “thought about

31.

ways to hide the leverage.”

The January 23 E-Mail contained a proposal that in many ways

resembled the proposal contained in the January 18 E-Mail

In the January 23 E-Mail, however,

the spread formula no longer contained an explicit multiplier as a mE?ns of incorporating

leverage

into the transaction.
32.

Under the terms of the proposal in the January 23 E-Mail, if Libor were to

trade above 5% during the first year of the transaction, the spread Lvould be equal to
(h-month Libor / 4 3 125%) -- 1
where

&month Libor is determined

expressed

as the di\,isor

le~eraeed

125’0”

Dividing the formula by 4 3 125’ o 1s marhematlcallv

3;

muitlplylng

“3 3

In thrs fc~rmula. the leverage is

at the end of the tirst !.ear

the formula

by 23 2

Accordingly.

the transaction

outlined

equl\~alent

In the Januan

to
23 E-Jta~i

I<

23 2 times
3-l

In the ei’ent

transactIon

outlined

component

of the transaction
35

in the January

that 1.1bor traded
23 E-hiall.

Lli70~~ 5” #IJurlng

rhe break-e\en

interest

the tirst ;.ear

oi the

rate for the spread

Lvould be -I 3 125’ o

By creating

dl\plsor that was also the break-even

a formula
Interest

In Lvhlch the lwerase

v.as expressed

rate for the spread component

I0

In the form oi <I

of the transaction.

Fonkenell was facilitating rhe stated objective of the marketer with whom he worked of hiding the
leverage.
Fonkenell knew or should have known

36
LDT

structure

transactions

outlined
to BT’s

in the January

prospective

23 E-hlail

that the marketer

to misrepresent

the material

would

use the

ofproposed

risks

clients

The Dharmala Transaction

A.

Marketing the Libor Barrier Transaction

1.

to Dharmala

Dharmala is an Indonesian holding company with subsidiaries engaged in

37

banking, finance and insurance
38
incurred

substantial

In

February of 1994, Dhartnala had an open transaction with BT that had

unrealized

losses

On or about

February

11. I QW,

suggesting 1:hat Dharnlala replace Its open transactlon

BT sent a proposal letter to Dharnlala
\\lth

a

Llbnr bamer SiL’ap(the “Februan

iJ

Proposal”)

The transactIon
of the proposal
exchange

Interest

outlined

in the Januan,

rate payments

contained
‘;
-.

E-\la~l

The customer‘s

In the February l-4 Proposal utilized the structure
.‘\t marunt\‘.
interest

BT nnd the customer

rate payment.

\+ouid

and thus the amount

the

’

customer owed BT, would increase by a “spread” if I,lbor crossed 5 25% during the tirst year ot‘
the

transaction
42

Under the terms of the February 14 Proposal. if Libor were to trade aboL*e

C 2SO.o during the first year of the transaction

the spread Liould be equal to

(h-month I.,ibor

-1 F”o’I

-

I

In this formula, as in the January 23 E-Mail, the leverage IS expressed as a divisor, in this case
IV,’
“4 5%”
43.

In the event that Libor traded above 5 259/o during the first year of the

transaction outlined in the February 14 Proposal, the break-even interest rate for the spread
component

of the transaction

was 4

5%

Thus. if durtng the tirst year of the transaction, Libor

traded above 5 35”; and remai ned aboi,e -1 !OO
component
.

of the transactlon

rose 5 25O/o and

Dharmala

then fell belo\+,

a pavment to Dharmala
1-l

DiL,tdlng

at

the end

ofthat

\i could LJ\L~ J L)dment

>‘ear, as to the spread

to HT

It: on the other

hand. I.~i?or

I

In a

46

marketing presentation

February 14 Proposal, the denominator

in the formula was represented

even interest rate for the spread component

This explanation fraudulently concealed the true

of incorporating

in the spread formula.

The true significance of the 4.5% denominatot_ls

47

a high degree of leverage into the transaction

requires that the spread formula incorporate
for the spread component
‘48
explanation
transactlon

sv.‘ap \\lth

transaction

to Dharmala as the break-

of the transaction in the event that Libor traded above

5 2596 during the first year of the transaction
significance of the denominator

regarding the transaction outlined in the

a denominator

that it serves as a means

Nothing in the transaction

equal to the break-even interest rate

of the transaction

The formula prepared by Fonkenell was used in conjunction

of that formula

in order

to misrepresent

the materlai

r-l&s of the Labor

with

this false

barrier s!+‘ap

to Dharniaia
4i)

On or about

February

\ ji

The transactIon

20. 1994, Dharmala

entered

Into a Labor barrier

BT

outlined

In the Februan

Dharmala

the \,alue of the Labor barrier
about .August

b\’ Dharmala

\\a~ .wb~t3nt1all\

slmllar

to the

1-l Proposal

7
_.

<j

executed

The Libor Barrier Trade Resulted
Losses to Dharmala and BT
5

Llhor txrrler s\sap rapIdI>, lost i alue

sUap \vas negatlk’e to Dharmala

I W4. the \,alue oi the trade had declined

Dharmala

I3

in Substantial

In or about

by approvmately

to approximately

:\pr~l

S38 million

negatl\‘e

SOS million

In or

to

Dharmala eventually tiled a civil action against BT in the Central Jakarta

52

District Court in Indonesia, styled P T Dharmala Sakti Seiahtera v Bankers Trust Company
Dharmala sought rescission of the Libor bamer swap as well as damages, based, inter aj&, on
alleged misrepresentations

regarding the manner m which the spread formula was to be calculated

BT later brought a law suit against Dharmala in the High Court of Justice, Queen’s Bench
Division in Britain, entitled Bankers Trust International
approximately

$65 million in damages.

PLC v. Dhacmala
Sakti Sejahtera, seeking
IF

BT ultimately settled its dispute with Dharmala in return

for a $12.5 million payment from Dharmala
53.

BT’s cost of the settlement with Dharmala was over $57 million to BT BT

also incurred substantial additional costs and expenses arising from the litigation and from
liabilities incurred in hedging

By conspiring

53
induce

Dharmala

financial

the transaction

to enter Into the Labor barrier

harm as Lvell as reputat~onal

I.
Adlnnl[ra

56

In rnlci-J,muan,
unrealized

57
suggesting

that Xdimitra

swap. Fonkeneil

in rhe fraudulent

scherllc

caused BT to incur

to

~ub~tantlai

Transaction

htarketing

SF

substantial

and particlpatins

harm

The Adimitra

R.

incurred

v, ith others

15 a company

the Libor

organized

of 1994. Adimitra

Barrier

under

Transaction

to Adimitra

the laws of Indonesia

had an open transaction

\\,lth BT that had

losses

On or about January
enter Into a Libor

3I

1994. BT sent a proposal

barrier

swap (the “January

letter

to .Adirnltra

3 1 Proposal”)

58

The marketer who requested that Fonkenell “hide the leverage” and to

whom Fonkeneli sent the January 23 E-Mail prepared or supervised the preparation of the January,
3 1 Proposal.
59

The transaction contained in the January 3 1 Proposal utilizes the structure

of the proposal outlined in the January 23 E-Mail. At maturity, BT and the customer would
exchange interest rate payments

The customer’s

interest rate payrgf)nt, and thus t& amount the

customer owed BT, would increase by a “spread” if Libor crossed 5% during the first year of the
transaction.
60

Under the terms of the January 3 I Proposal, if Libor were to trade above

5% during the first year of the transaction, the spread would be equal to
(6-month Libor ’4 3’%) - 1
In this formula, as in the Januanr 23 fC-\lall. the ieverase IS expressed as a divisor, in this case

61

In the e\ ent that Labor traded ab0L.e 5’o during the first year of the

transaction outlined in the Januan

; I Orc)pl>saI.the break-e\,en Interest rate for the spread

component of the transaction \\ a\ 1 ;’ ,>
61
the formula bv 23 i

Dividing the

t;lrmula

by

1 ~O,O 15

mathematically equivalent to multiplyng

Accordingi~. :he [ransactlon ourlined in the January 3 1 Proposal IS le\ eragrd

23 3 times
63

Upon Informat\on and belief. in a marketing presentation

transaction outlined in the Januan, 3 I Proposal. the denominator

regardmg the

in the formula was represented

.

to Adimitra as the break-even

interest rate for the spread in the event that Libor traded above 54’;

during the first year of the transaction.
significance of the denominator

in the spread formula

The true significance of the J 3O/
/o denominator

64
of incorporating

This explanation fraudulently concealed the true

a high degree of leverage into the transaction

requires that the spread formula incorporate

a denominator

IS that it serves as a means

Nothing in the transaction

equal to .$e break-even irtterest rate

for the transaction.
65.

The formula prepared by Fonkenell was used in conjunction

explanation of that formula in order to misrepresent

with this false

the material risks of the Libor barrier swap

transaction to Adimitra.
66

On or about February 28. 1994, .Adlmltra entered into a Libor barrier swap

67

The transactlon executed by .-Idimi;ra i+as substantially similar to the

transaction outlined in the Januan
7
_.

3 I Proposal
The Libor
to hdimitra

fJ,s

Barrier

Trade

Resulted

in Substantial

Losses

and BT

Adimltra‘s Libor barrier s\\‘ap rapIdly lost iaiue

199-I~BT’s internal valuation of the transaction was approuimatelv

In or about December

negative $75 million to

.Adimrtra
69

Adimitra eventually filed a civil actlon against BT in the United States

Dlstrlct Court for the Southern District of New
Hankers Trust Colnpaal

I’ork, styled p T .Adimitra Rayarxatamau

.Adlmltra sought reclsslon oi the L.ibor barrier swap as well as damages.

1

alleging that BT had committed

fraud by hiding the leverage in the Libor barrier swap and

otherwise concealing the material risks of the transaction

BT ultimately settled its dispute with

Adimitra.
70

The cost of the settlement with Adimitra was approximately

$49 million to

BT. BT also incurred substantial additional costs and expenses arising from the litigation and
from liabilities incurred in hedging the transaction.
71.

L’

In creating an LDT structure in which the leyerage was hidden, Fonkenell

acted together with others to defraud BT’s clients by misrepresenting

the material risks of the

transaction.

m.

Falsifviw BT’s Books and Records So As To Misstate the Profit in the
Transaction

71
:_

On or about YUoL,ember3, 1993, BT entered into an LDT \vtth Proctor

Gamble, Inc (the “P&G Trade”)
option,
received

referencing

In ett‘ecr Itshen P&G entered

both the 30-,,ear

by P&G was embedded

Treasuv

the transaction.

bond and the 5-year Treasury

CC

it sold BT an

note

The premium

into a su’ap

option pnclng
74
recorded

Fonkeneil

\+‘as responsible

on BT’s books and records

was responsible

for ensuring

on the 5-year and the 30-year

for ensuring

In connection

that the P&G Trade was accurateI>

\\lth recording

the P&G Trade,

that BT valued the trade usmg appropnate
Treasuries

\folatilities

Fonkeneil
for the option

Prior to the entry of the P&G Trade, BT’s books and records reflected that

75.

the volatility for the 5-year Treasury was I8 per cent and the volatility for the 30-year Treasury
Fonkenell was aware that. at these levels, the P&G Trade would be valued such

was ten per cent.
that

BT’s books and records would

transaction.

a profit of apnroximately

reflect

This profit would have been recorded

$12 to 13 million for the

as “new deal” profit on BT’s books and

records.

L’.
76.

Fonkenell reduced artificially the amount of new deal profit generated by

the P&G Trade, intending to capture that profit at some later point as trading profit and thereby
provide management

with a more favorable

impression

of

also aware that BT’s bonus period would end on November
77

In furtherance

direct

supen4sor

that

profit,

he had informed

his abilities as a trader.
30.

of hrs scheme, on or about

Yovjember

2, Fonkenell

while the P&G Trade \i.ould generate approximately
the marketer

\tho

Fonkenell was

S I2 to 13

told

million II

~sorked on the trade that the trade \+,ould only generate

$7 5 million
[_ater In the dav 11rl \o~ember

78
Lvith a colleague

who \vas emplo>,ed
[I]t

will

million
anvbody
Fonkenell

like. S IO mrliron

So the otfictal
asks t*ou

then asked his colleague
79

from

show

in the operations

Fonkenell

number

2. Fonkrneli

area of BT

but the marketers

dtscussed
Fonkeneli
know

the

P&G transacti~~n

stated

tt at $7

is. like. a bit more than 7

if

e\-en the controllers
to reduce the \~olatrlrtres used to price the
requested

that the \~olattlitl;

I 0 per cent to 9 per cent and that the j olatility

IS

on the 30-year

on the 5-year Treasury

P&G Trade
Treasury
be reduced

be reduced
from

Is

per cent to 17 percent.
approximately

This would result in reducing new deal profit for the trade by

$3 million.

Fonkenell then stated, “[a]nd tomorrow,

remind me tomorrow,

we’ll

move up the bond.”
80.

Fonkenell’s

professional judgment

request

the volatilities be lowered was not based on his

that

regarding market factors, but was instead the result of his desire to lower

artificially the new deal profit for the P&G Trade
81.

L”

Fonkenell stated that he had prospectively

volatility parameter the day after it was lowered
input to BT’s computer

determined to “move up” a

Fonkenell’s actions in altering the volatility

modeling system, without regard to market factors, created a situation in

which BT could not accurately determine the value of certain derivative transactions
of time
adversely

This inability
affect

BT’s

to determine

risk management
Pursuant

82
for the j-year

and the j&year

Trade was approxImateI?

to Fonkenell’<
Treasunes

marked.

$6 7 m~ll~or

affected,

or had the potential

to

operation
Instructions.

his collea_ge

lowered

a[ ihe close of the da>. on November

The new deal pr\>tit rx~~rded

3’
<s

been properly

such L,alues adversely

for a period

on BT’s

tt,d the \olatllltles

the new deal protit

entered

on BT’s

books

and records

the \,olatilities

2
for the P&G

for the 5->,ear and 3@-year Treasuries
books

and records

would

have been In

excess of S 10 million
84
year Treasury
recorded

The next da!,. Lo~er-nbrr

was increased

on BT’s

books

to I8 per cent

and records.

3. as Fonkenell

This increase

to increase

intended.

the \,olatilit>,

caused the value of the P&G

app;oximatelv

S 1 5 million

of the 5.
Trade.

as

85

On or about November 9, 1993, at Fonkenell’s request, the volatility of the

30-year Treasury was raised to 10 per cent. BT’s books and records indicate that BT earned over
$2 million in profit generated by this increase.
86
professional judgment

Fonkenell’s request that the volatilities be raised was not based on his
regarding market factors, but was instead the result of his need to return

the volatilities to market levels after artificially causing them to be layered
87.
created the appearance

The increases in volatility orchestrated

by FoAkenell on November 3 and 9

that Fonkenell was generating profit through his trading activities.

a significant portion of this profit should have been recorded

as new deal protit

from the

In fact,
P&G

Trade
88
of

By intentionally causing false entries to be made on the books and records

BT n,ith the inrent to mislead and defraud

prohibition

on making

false entries

on a bank’s

He also engaged in unsafe-and-unsound
to

B-I’

BT and its ernplo~ et>. Fonkenell

bankins

books

and records

practices

contaIned

and breached

I lolated

the

in I S I’ S C 3 1005

his fiduciary

duties

FONKENELL’S

MISCONDUCT

A. Fonkenell Committed Wire Fraud and Engaged in Unsafe-and-Unsound
Banking Practices and Breaches of his Fiduciary Duties in Connection
With the Sale of the Libor Barrier Trades to Adimitra and Dharmala
As set forth in paragraphs 4 through 71 above, Fonkeneil violated the

89

prohibitions of the federal wire fraud statute, 18 U.S.C
defraud BT’s customers
of transactions

by participating

in and facilitating the misrwesentation

that were sold to those customers.

an unsafe-and-unsound

5 1343, when he conspired to and did
of material risks

Fonkeneli’s fraudulent conduct also constitutes

banking practice and a breach of Fonkenell’s fiduciary duties to Banker’s

Trust
B. Fonkenell Violated the Law and Engaged in Unsafe-and-Unsound
Banking Practices When He Caused False Entries to Be Made On the
Books and Records of BT In Connection With the P&G Trade
90

As set forth In paragraphs 4 through 20 and 72 through 88 abo\,e,

Fonkenell violated the prohibttion against making false entries on a bank’s books and records
contained in 18 U S C 4 1005 \\,hrn he caused false entries to be made on BT’s books and
records with the Intent to deiraud F-1’hi, x-tlficlallv inflating his bonus
also engaged in unsafe-and-ilnsolind

In so doing, Fonktzncll

h,inhlng practices and breached his fiduc1ar-y duties to RT

ASSESSMENT
91

(a)

Section

OF CIVIL

PENALTIES

8(i) of the FDI Act, I2 U S C 3 I8 18(i), authorizes the

assessment of civil money penalties in the amount of $5.000 per day against an institutionaffiliated party who violates any law or regulation
(b) Section 8(i) of the FDI Act, 12 U S C $J818(i),

authorizes the

assessment of civil money penalties in the amount of $25,000 per day against an institutionaffiliated party who violates any law or regulation,

recklessly engages in any unsafe or unsound

practice, or breaches any fiduciary duty which violation. practice, or breach is part of a pattern
of misconduct,

causes or is likely to cause more than a minrmal loss to a depository

institution, or

results in pecuniary gain or other benefit to such part!
(a) Fonkenell‘s consprracy to defraud BT‘s customers commenced

92

on or

about January 18. 1994 and continued to at least February 20. 1994 as to Dharmala. and to at
least February 28. 1994 as to Adimitra
(b) Fonkeneli‘s actions in causrns false entrees to be made on BT’s books
and records commenced

on or about SoL,ember 2, iii98 2nd contrnued to at least November ~1.

1938
93
enraged
._ L. in violations

(a) As set forth in this Notice. Fonkenell knowingil; and recklessl>

oflaw,

unsafe and unsound practrces. and breaches of tiduciaw duties b\

partrcrpating in a scheme to defraud BT’s lndonesran customers

These violations of laws unsafe

and unsound practices and breaches of fiductarv duttes caused more than a minimal loss to BT by

subjecting BT to substantial litigation risk. Moreover,
to pay significant amounts in connection

Fonkenell’s fraudulent conduct caused BT

with BT’s hedging costs and the litigation which arose

from that misconduct
(b) As set forth in this Notice, Fonkenell knowingly and recklessly
engaged in violations of law, unsafe and unsound practices, and breaches of fiduciary duties by
causing false entries to be made in BT’s books and records.
94.

W

After taking into account the size of Fonkenell’s financial resources, his

lack of good faith, the gravity of the violations described herein, his history of previous violations,
and such other matters as justice may require, the Board of Governors hereby assesses a civil
money penalty of Two Hundred Fifty Thousand Dollars ($250,000) against Fonkenell for
(a) conspiring to and engaging in a scheme to defraud in connection

with the sale and marketing

of LDTs to Adimttra and Dharmala. and (b) manipulating the books and records of BT in
connection with the P&G transactlon for his own benefit and in a manner which ivas adverse to
BT’s risk management
35

systems
The penalties set forth In paragraph

Governors pursuant to Sectlon S(i)

of the

3-l hereofare

assessed by the Board of

FDI Act. IS I’ S C j IS 18(i) Remittance ofthe

penalties set forth herein shall be made Lvithin 60 days of the date of this Notice. in immediately
available funds, payable to the order ofthe Secreta?
Reserve System. Washington,
of the United States

of the Board ofGovernors

of the Federal

D C 2055 1, who shall make remittance of the same to the Treasur),

Notice is hereby given, pursuant to section 8(i)(2) of the FDI Act (12

96

U S C 5 1818(i)(2)) that Fonkenell is afforded an opportunity
Board of Governors

concerning

civil money penalty assessment

this assessment

for a formal hearing before the

Any request for a hearing with regard to this

must be filed with the Secretary of the Board of Governors,

Washington, D.C 2055 I, within 20 days after issuance and service of this Notice.
In the event Fonkenell fails to request a heariw within the aforementioned

97.

20-day period, Fonkenell shall be deemed, pursuant to section 263. L9(c)(2) of the Rules of
Practice, to have waived the right to a formal hearing, and this Notice shall, pursuant to
section 8(i)(2) of the FDI Act, constitute

a final and unappealable order

CEASE-AND-DESIST
98

By reason of the misconduct

referenced in paragraphs 89 and 90 above, a

cease and desist order pursuant to section S(b) of the F-III Act. I:! L. S C $ 1S 18(b), should be
Issued against Fonkenell as a result of his \,lolations o<la..i,. unsafe and unsound practices, and
breaches of fiduciary duties in conspiring
to be made on BT’s

books

evidence

New York,

on the charges

at the Federal

Kesen,e

hereinbefore

specified

to cease-and-desist

should

requiring

to cease and desist from

Fonkenell

BT’s

customers

and in causing

false entrles

and records

Notice is herebl, _elien

99

New York,

to defraud

be issued pursuant

that a hedrlng

v.~li be heid on December

Bank of New t’ork.
In at-de: to determme
to witlc?n

S(b) ofthe

for the purpose

2s. IWS.

of taking

b+rhether an appropriate
FDI Act,

ITI

13 Ly S C

order

ISIS(b).

(a) serving in any capacity as an institution-afflliared
agency specified in Section 8(e)(7)(A)

Act , 12 U S C

of the FDI

bank, a bank holding company, or nonbank subsidiav,
(b) serving
Section

8(e)

as an institution-aff3iated

(7) (A) of the FDI Act,

party of an institution or
$ 18 18(e)(7)(A),

without Federal Reserve approval, and

party of any institution

12 U.S.C.

including a

$ 18 18 (e) (7) (‘4).

or agency

specified

in

including a bank, bank holding

company, or nonbank subsidiary, where his duties include, directly o;,indirectly- (1) participating
in the structuring of derivative transactions

for marketing or sale to Fustomers; (2) advising any

customer regarding the purchase, sale or structuring of a derivative transaction; (3) preparing
marketing materials regarding derivative transactions
PROCEDURES
I@0

Fonkenell

of the sem~ce of this Notice,
$ 363 19. with

the OffIce

N U’ ( Washington.
C F R 4
Board

is hereby

as prn\,ided

Pursuant

D C 20551

.-Is provded

herein shall constitute

NotIce.

and authorization

alleged

In the Notice

declslon

a waiver

and to file icith

‘63

(the “OFI,4~~).

263 I 1(a) of the

the Secretary

and appropriate

on the Secretan,

motion.

of the Board

of Governors

conclusions

12
of the

12 C F
within

the allegations

upon proper

20 days

12 C F R

of Practice.

by this Notice

to appear and iontest

within

1700 G Street.

1‘)I c H I ) of the Rules of Practice.

of his right
otTicer,

Rules

shall also b e ien,ed

to tile an .-\ns\ver required

for the presiding

containing such findings

r\djudication

to sectlon

In section

to this Notice

26.: 19 of the Rules of Practice.

tiled is.ith the OFl:‘i

$ 263 l9(c)( I ), the failure of Fonkenell
proL,ided

to file an .4nswer

by section

of Financial Institution

263 I l(a), any .\nswer

ofGo\,ernors

directed

R

the time
of the

to find the facts as
a recommended

1

101
judge to be appointed

The hearing described above shall be held before an administratrve Iau
from the OFIA, pursuant

to

section 263 54 of the Board of Governors

Rules of Practice for Hearing (the “Rules of Practice”),
public, unless the Board of Governors

12 C F R 5 263 54. The hearing shall be

determines that a public hearing would be contrary to the

public interest, and in all other aspects shall be conducted

in compliance with the provisions of the

FDI Act and the Rules of Practice.
102.

Fonkenell may submit, within 20 days of the service of this Notice, to the

Secretary of the Board of Governors,

a written statement detailing the reasons why the hearing in

this proceeding

The failure to submit such a statement within the aforesaid

should not be public

period shall constitute
103

a waiver of any objection to a public hearing
.Authority is hereby delegated to the Secretary of the Board of Governors

to take any and all actions that the presidiny ofiicer would be authorized to take under the Board
of Governors’ Rules of Pracuce with respect to thus Notice and any hearing conducted thereon.
until such time as the presiding ofIicer shall be designated by the 0FI.A as prov,ided hereon

Dated at 15’ashrngton. D C thls?gTdav

of.Lc*

13QS

BOARD OF GOVERWORS OF THE
FEDERAL RESERVE SYSTEhl

Secretary of the Board

I

UNITED STATES OF AMERICA
BEFORE THE BOARD OF GOVERNORS

OF THE FEDERAL RESERVE SYSTEM

WASHINGTON,
_-_--___-__________________

---

D.C

-,y

Docket No. 98-032-B-I
98-032-CMP- I

In the Matter of
GUILLAUME HENRI ANDRE
FONKENELL
An Institution-Affiliated
Party of
BANKERS TRUST COMPANY
New York, New York
____-__-______-________________x

APPROVAL OF AMENDMENT TO NOTICE OF CHARGES AND OF HEARING
AND NOTICE OF THE ASSESSMENT OF A CIVIL MONEY PENALTY
Pursuant to section 265.4 of the regulations promulgated

by the Board of Governors

of

the Federal Reserve System (“the Board”), 12 C.F.R. $ 265.4. I approve the following
amendment to the Notice of Charges and of Hearing and Notice of Assessment
Money Penalty that was issued by the Board in this proceeding

of a Civil

on October 29. 1998 (“Original

?i’otice”):
1. Paragraph 99 of the Original Notice is deleted
3 New paragraph 99 provides:

I.

“99.

Notice is hereby given that a hearing Lvill be held on December 28, 1998, in

ye\+, York, New York, at the Federal Reserve Bank of New York, for the purpose of taking
evidence on the charges hereinbefore

specified in order to determine whether an appropriate

order to cease-and-desist

should be issued pursuant to section 8(b) of the FDI Act, 12 U.S.C.

$1818(b):
(a) requiring Fonkenell to cease and desist from serving as an institution-affiliated
party of any institution or agency specified in Section 8(e)(7)(A) of the FDI Act, 12 U.S.C. $
18 1W(7)(A),

including a bank, bank holding company, or nonbank subsidiary, where his duties

include, directly or indirectly: (1) participating
marketing or sale to customers;

(2) advising any customer regarding the purchase, sale or

structuring of a derivative transaction;
transactions;

in the structuring of derivative transactions for

(3) preparing marketing materials regarding derivative

and
(b) ordering other appropriate restrictions on Fonkenell’s

institution-affiliated

future activities as an

party as are warranted based on the record in this proceeding.”

7

Dated at U’ashington, D.C. this

7-c
-~ day of May, 1999

BOARD OF GOL’ERVORS OF THE
FEDERAI RESERVE SYSTEM