The UK Financial Conduct Authority barred Jonathan Burrows, a former managing director of Blackrock Asset Management Investor Services Limited, from engaging in any regulated activities because he failed to pay train fares in connection with his commuter rail transport to London for an unspecified time period, prior to the time he was caught by an officer on November 19, 2013. According to the FCA, Mr. Burrows was banned because he “is not fit and proper” to carry on regulated entities “because he lacks honesty and integrity.” Mr. Burrows apparently admitted to the relevant transit authority that” he had evaded his train fare on a number of occasions and had done so in the knowledge that he had been breaking the law,” and paid a fine which he claimed exceeded the amount of fare he evaded paying. However, Mr. Burrows apparently did not advise his employer of his misconduct—although the FCA did not charge him related to this. Mr. Burrows consented to the sanction.

Culture and Ethics: This much-reported episode has engendered quite a few raised eyebrows and a fair amount of head shaking by those reading about it. That being said, I am still surprised at the harshness of Mr. Burrows’ penalty in light of the scope of his malfeasance and the seemingly unrelated nature of his actual misconduct to his regulated activity. Few would disagree that those who engage in unscrupulous behavior in our industry, or even unrelated felonies, major crimes, or even certain crimes of moral turpitude are appropriate subjects of harsh sanctions including registration or trading suspensions, let alone prohibitions. However, at some point enough is too much. Frankly, as much as what Mr. Burrows did to evade payment of his transit fares was very wrong (and seems quite arrogant too), it’s a credit to him that he consented to this seemingly disproportionate sanction. Anyone, besides me, humming Arlo Guthrie's 1967 hit song Alice's Restaurant (released by Warner Bros./Reprise)?