The Man From FCPA had not heard the term ‘front-loading’ for some time. It may well have been as far back as the Bernie Madoff scandal, when whistleblower Harry Markopolos thought one of the schemes that Madoff was using was to front-load the sales of stock to come up with his annual 20% return rate. It turned out that even Markopolos could not imagine Madoff was running a $60bn Ponzi scheme. Yet front-loading is still an illegal scam. Unfortunately for U.K. bank HSBC, it appears two of its foreign currency (forex) trading executives in the United States were engaging this scheme.
