The Dubai Financial Services Authority has imposed a $20,000 fine and a six-year ban from financial services on an asset manager who forged signatures, lied to his managers, lied to his client, undertook millions of dollars' worth of investments unauthorised by his firm, the regulators, the law and his client, and produced false account statements.

The Dubai Financial Services Authority has imposed a $20,000 fine and a six-year ban from financial services on an asset manager who forged signatures, lied to his managers, lied to his client, undertook millions of dollars' worth of investments unauthorised by his firm, the regulators, the law and his client, and produced false account statements.

The enforceable undertaking that Nikhil Das signed with the DFSA recently is full of mystery. Almost the entire story of Das's egregious and not entirely sober-minded career as an asset manager is missing from the document. It does not say what firm he worked for, who his client was, or how his unauthorised trades - one for US$1 million in a fixed maturity plan, one for US$3.266 million in a switchable SKEW note - led to no losses. On the positive side, it does state that Das caused his client no loss (although the mechanics of this happy outcome go unexplained) and co-operated fully in the subsequent investigation.

Das has been judged not to be a fit and proper person to undertake financial functions according to Article 58(1) of the Regulatory Law. He admits dishonestly contravening Articles 54(c) and 55 of the Markets Law of 2004.

One interesting clause of the contract (32) states that if the DFSA decides not to enforce any part of it, nobody else can do so either. The clause states: "A person who is not a party to this Enforceable Undertaking has no rights...to enforce any term of this Enforceable Undertaking."

With no criminal prosecution for false accounting or any other offence on the horizon, Das has merely to wait six years until his undertaking "not to perform any functions in or in connection with the provision of financial services in the Dubai International Financial Centre" lapses. Some commentators are wondering whether he has friends or relatives in high places.