Ian Hannam was given final written warning by JP Morgan Cazenove before FSA fine The internal investigation closed some two and a half years before the FSA issued its decision notice against Mr Hannam in April 2012, but was triggered by the regulator alerting the bank of its own examination of his role. Mr Boulton said that Mr Hannam had passed on inside information, and that the FSA's original decision in the matter should stand. "Improper disclosure of inside information is a very serious offence because it severely undermines the integrity of markets and therefore damages confidence in markets," he concluded. The FSA's original case was based on two emails - sent by Mr Hannam in September and October 2008 - in which he passed on information related to a merger between Heritage Oil and Genel Enerji, the Kurdish oil company. Mr Hannam, who is attempting to overturn the FSA's original ruling, used the FSA's own investigation into him as part of his defence. In his opening argument, Laurence Rabinowitz QC said the FSA "had at least three attempts at formulating a case of market abuse" against Mr Hannam. Mr Rabinowitz argued that the recipient of the emails - Ashti Hawrami, the Kurdish natural resources minister - was already an insider because of the nature of his position and his proximity to the proposed merger. In his opening remarks, Mr Rabinowitz also said that when Mr Hannam left the firm in September last year, he had to "forgo substantial sums" - believed to be between £12-27m - stemming from to 2008/9 bonuses as part of his termination arrangements. The tribunal continues.