UK Financial Conduct Authority (FCA) Issues H2O AM ex-Deputy CEO Jean-Noel Alba Permanent Ban & $1.4 Million Fine for Lack of Integrity & Misleading UK FCA, UK Asset Manager H2O AM Ordered to Pay $274 Million (€250 Million) to Investors for Due Diligence Failure on Investments Relating to Tennor Group of Companies Owned or Introduced by Lars Windhorst, Investments Were High Risk & Hard to Sell, H2O AM Had Received But Not Declared Use of Superyacht & Private Jet by Employees, Provided False & Misleading Information to Regulator, H2O AM to Waive Rights to Fees & Investments of €320 Million & to Stop Operating Regulated Business in UK
27th July | Hong Kong
The UK Financial Conduct Authority (FCA) has issued H2O AM ex-Deputy CEO Jean-Noel Alba a permanent ban & $1.4 million fine (£1.0495 million) for lack of integrity & misleading UK FCA. In 2024 August, UK asset manager H2O AM was ordered to pay $274 million (€250 million) to investors for due diligence failure on investments relating to Tennor Group of companies owned or introduced by Lars Windhorst. The investments were high risk & hard to sell. H2O AM had also received but not declared use of superyacht & private jet by employees, and provided false & misleading information to regulator. H2O AM agreed to waive rights to fees & investments of €320 million, and to stop operating regulated business in the UK. UK FCA (25/7/25): “The former deputy chief executive officer of asset manager H2O AM LLP (H2O), Jean-Noel Alba, has been fined £1,049,500 by the FCA and banned from the financial services industry. An FCA investigation found that Mr Alba lacked integrity because he misled the FCA. Between April 2015 and November 2019, H2O failed to carry out proper due diligence on investments relating to the Tennor Group of companies owned by Lars Windhorst, or companies he introduced. The investments were high risk and hard to sell, leaving investor money trapped. In 2024, the FCA agreed that H2O would pay those investors €250 million. During the FCA’s investigation into H2O, Mr Alba provided false and misleading statements and documentation to the regulator. Mr Alba was the principal point of contact with the FCA during its investigation. Mr Alba asked junior colleagues to create minutes, including records and minutes of committees, where no formal meetings had taken place. Mr Alba also provided due diligence materials, such as investment research, to the FCA that had been created years after the investments had been made, when he had claimed they were produced at the time.”
“ UK Financial Conduct Authority (FCA) Issues H2O AM ex-Deputy CEO Jean-Noel Alba Permanent Ban & $1.4 Million Fine for Lack of Integrity & Misleading UK FCA, UK Asset Manager H2O AM Ordered to Pay $274 Million (€250 Million) to Investors for Due Diligence Failure on Investments Relating to Tennor Group of Companies Owned or Introduced by Lars Windhorst, Investments Were High Risk & Hard to Sell, H2O AM Had Received But Not Declared Use of Superyacht & Private Jet by Employees, Provided False & Misleading Information to Regulator, H2O AM to Waive Rights to Fees & Investments of €320 Million & to Stop Operating Regulated Business in UK “
Notes:
- Read the final notice (PDF)
- The FCA investigation found that Mr Alba breached APER Statement of Principle 1 (failed to act with integrity) and Statement of Principle 4 (failed to deal with the FCA in an open and cooperative way); and Individual Conduct Rule 1 (failed to act with integrity) and Individual Conduct Rule 3 (failed to deal with the FCA in an open and cooperative way).
- The FCA previously announced H2O would pay €250 million to affected investors following its investigation. Following its application to voluntarily cancel its permissions in the UK, H2O is no longer authorised in the UK. Mr Alba was previously identified in the final notice as ‘Senior Manager A’.
- The French financial services regulator, the Autorité des marchés financiers (AMF), is the designated regulator in respect of the collective investments, which H2O had managed on a cross-border basis pursuant to the UCITS Directive.
UK Asset Manager H2O AM to Pay $274 Million (€250 Million) to Investors for Due Diligence Failure on Investments Relating to Tennor Group of Companies Owned or Introduced by Lars Windhorst, Investments Were High Risk & Hard to Sell, H2O AM Had Received But Not Declared Use of Superyacht & Private Jet by Employees, Provided False & Misleading Information to Regulator, H2O AM to Waive Rights to Fees & Investments of €320 Million & to Stop Operating Regulated Business in UK
16th August 2024 – Following UK Financial Conduct Authority (FCA) investigation, UK asset manager H2O AM will pay $274 million (€250 million) to investors for due diligence failure on investments relating to Tennor Group of companies owned or introduced by Lars Windhorst. The investments were high risk & hard to sell. H2O AM had also received but not declared use of superyacht & private jet by employees, and provided false & misleading information to regulator. H2O AM agreed to waive rights to fees & investments of €320 million, and to stop operating regulated business in the UK. UK FCA (7/8/24): “Asset manager H2O AM LLP (H2O) will pay €250 million to investors unable to access their funds since 2020, following an investigation by the FCA. Between April 2015 and November 2019, H2O failed to carry out proper due diligence on investments relating to the Tennor Group of companies owned by Lars Windhorst, or other companies he introduced. The investments were high risk and hard to sell. The FCA also found that H2O did not have adequate policies or procedures or exercise due skill and care in managing potential conflicts of interest. The FCA identified over 50 instances where hospitality had been received by H2O employees but was not properly declared, including the use of a superyacht and private jet. H2O also provided false and misleading statements and documentation to the regulator, such as fabricated records and minutes of meetings. The FCA would have imposed a substantial fine on H2O for its serious breaches. However, the FCA has agreed the firm will make €250 million available to all those whose investments remain trapped. A significant part of this sum has been made available by way of voluntary contribution from the H2O Group. H2O has waived its rights to fees and investments totalling €320 million and will apply to cancel its UK authorisation by the end of the year.” Steve Smart, joint Executive Director of Enforcement and Market Oversight: “H2O’s job was to manage its funds properly and protect investors. It failed to do this and, to make matters worse, it repeatedly provided misleading information to the FCA.”
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