NEWSLETTER-2019-metin

98 NEWSLETTER 2019 exchange, as a form of horizontal cooperation between competitors may create efficiency gains, it can also lead to restriction of competi- tion. Based on the Commission’s investigation in the market, it was re- vealed that some individual traders in charge of the Foreign Exchange (“Forex”) spot trading of 11 currencies on behalf of the relevant banks exchanged commercially sensitive information, as well as trading plans. Also, it was found that these traders, who were direct competi- tors, occasionally coordinated their trading strategies through various online professional chatrooms, like the Bloomberg terminals, through- out entire working days. The commercially sensitive information exchanged in these cha- trooms related to: (i) Outstanding customers’ orders (i.e. the amount that a client wanted to exchange, and the specific currencies involved, as well as indications on which client was involved in a transac- tion); (ii) Bid-ask spreads (i.e. prices) applicable to specific transacti- ons; (iii) Their open risk positions (the currency that was needed to buy or sell in order to convert their portfolios into their bank’s currency); and (iv) Other details of current or planned trading activities. As per the above, it was clear that the traders had extensive con- versations about a variety of subjects, including recurring updates on their trading activities. With these exchanges of information between the participating traders, they could coordinate with each other and were informed of market decisions as to whether to buy or sell the currencies they had in their portfolios, and when. As a result of its investigation, the Commission was made aware of two separate infringements concerning foreign exchange spot trad- of the European Union to horizontal co-operation agreements (2011/C 11/01), para.1.