THE LONDON METAL EXCHANGE

The London Metal Exchange nickel crisis is an accountability case because the most visible act, cancelling a full morning of trades, came after less visible controls had failed to contain an accelerating market disorder. Courts ultimately upheld the cancellation as a lawful emergency response. The Financial Conduct Authority later found that the exchange had lacked adequate controls, policies and staff preparation for the conditions that made that response necessary. The lasting question is therefore not whether an exchange can act in an emergency. It is whether the operator, its clearing house, members and regulators can show who controlled each risk before, during and after the emergency, and whether repairs can be proved under stress rather than merely announced.