Banque Havilland

Banque Havilland was a Luxembourg private bank whose London branch became associated with a leaked 2017 document describing a possible strategy to place pressure on Qatar's currency and securities markets. The document and later regulatory action make the bank relevant to economic warfare, but public evidence does not establish that the proposed trades were executed or directed by a state.

The bank was created in 2009 after Rowland family interests acquired assets from Kaupthing Bank Luxembourg. In November 2017, The Intercept published a presentation prepared by a Banque Havilland employee. It described transactions involving Qatari bonds, derivatives and the riyal. Banque Havilland denied conducting currency manipulation. Qatar later advanced allegations in civil proceedings. Pleadings and leaked documents are not findings of fact.

On 3 February 2026, the Upper Tribunal upheld the Financial Conduct Authority's findings that the bank and two former employees had acted without integrity in creating the plan, and that they intended to present the strategy to a representative of Mubadala. It upheld their prohibitions and determined penalties of GBP 4 million for the bank, GBP 352,000 for Edmund Rowland and GBP 14,200 for Vladimir Bolelyy. The judgment did not establish that the proposed trades were executed or directed by a state.

On 1 August 2024, the European Central Bank withdrew the bank's authorisation after a proposal by Luxembourg's supervisor. On 9 August, the Luxembourg District Court confirmed a suspension of payments and appointed administrators to control the bank's assets. Those regulatory steps ended the bank's authorised operation, but they were separate from the United Kingdom tribunal's findings about the Qatar plan.

The case distinguishes three propositions: the bank created the plan and intended to present it to a Mubadala representative; execution has not been established; and state direction has not been established. Collapsing those propositions would overstate the record.

See also

Banque Havilland plan to manipulate the Qatari riyal, 2017-2026 · Qatar Central Bank · Currency-peg attack · Market-based warfare · Bank licence withdrawal

Sources

1. UK Financial Conduct Authority, Banque Havilland decision notices, published 5 May 2023.
2. European Central Bank, list of supervised entities and licence decisions.
3. The Intercept, leaked Qatar market document, 9 November 2017.
4. UK Financial Conduct Authority, Upper Tribunal upholds findings in Banque Havilland case, 3 February 2026.
5. [Upper Tribunal, Banque Havilland SA and others v Financial Conduct Authority, [2026] UKUT 47 (TCC), 3 February 2026](https://assets.publishing.service.gov.uk/media/6981fbeee833d031a3158f91/Banque_Havilland_and_others_v_The_FCA_Final_Decision.pdf).
6. Commission de Surveillance du Secteur Financier, licence withdrawal, 2 August 2024.
7. Commission de Surveillance du Secteur Financier, suspension of payments, 9 August 2024.