# The LME Nickel Trading Suspension (2022) > The LME nickel trading suspension was the episode in March 2022 in which nickel futures prices surged on the London Metal Exchange (LME), leading to a halt in trading and the cancellation of trades. The UK courts later held the cancellation lawful, and the UK financial regulator fined the LME over its controls. - URL: https://www.derivatives-compass.org/en/history/lme-nickel-suspension/ - Area: History › Major Events - Last reviewed: 2026-10-23 - 日本語版: https://www.derivatives-compass.org/ja/history/lme-nickel-suspension/index.md ## Key points - Nickel futures surged from March 4 to March 8, and the LME suspended trading on March 8. - As the price rose, margin calls on members with short positions grew to record levels. - Leaving the trades in place risked several members being unable to pay, so the LME canceled trades from 00:00 on March 8. - The LME's independent review listed several factors, including a build-up of short positions and a sudden drop in the volume available to trade. - The courts held the cancellation lawful, and the FCA fined the LME over its controls, including price bands. The suspension of nickel trading at the [London Metal Exchange (LME)](https://www.derivatives-compass.org/en/glossary/london-metal-exchange/) is a reference case for work on estimating the margin a [clearing house](https://www.derivatives-compass.org/en/glossary/central-counterparty/) will call, and on an exchange's powers to halt trading and cancel trades. It is also a real example for staff who monitor members' funding or manage metals positions when markets move to extremes. ## What happened From March 4 to March 8, 2022, the price of the LME's 3-month nickel futures rose to more than three times its starting level. The 3-month contract is a [futures contract](https://www.derivatives-compass.org/en/glossary/futures-contract/) settled by physical delivery in three months, and it is the most liquid contract among the LME's [base metals](https://www.derivatives-compass.org/en/glossary/base-metal/) futures[^nickel-fca-22]. At 08:15 on March 8 (London time; all times below are the same), the LME [suspended trading in the nickel market](https://www.derivatives-compass.org/en/timeline/#event-lme-nickel-suspension). At 12:05 the same day, it announced that it would cancel nickel trades concluded from 00:00 on March 8[^nickel-ca-70]. The market reopened at 08:00 on March 16[^nickel-ca-72]. The notional value of the canceled trades was USD 13.373 billion[^nickel-fca-4105]. Two groups of parties to the canceled trades, who said they had lost profits because of the cancellation, brought court claims against the LME and its clearing house, LME Clear. They were Elliott Associates L.P. and Elliott International L.P. (together, Elliott), and Jane Street Global Trading, LLC. Both argued that the decisions of the LME and LME Clear were unlawful. The High Court (a Divisional Court) and the Court of Appeal rejected their claims by October 2024[^nickel-ca-6][^nickel-ca-176]. In March 2025, the Financial Conduct Authority ([FCA](https://www.derivatives-compass.org/en/glossary/fca/)) fined the LME because its controls were not adequate[^nickel-fca-11]. ## The roles of the exchange and the clearing house The LME is a venue for trading industrial metals and a recognised investment exchange under the UK Financial Services and Markets Act 2000[^nickel-ca-10]. LME Clear is the clearing house that takes on every trade concluded on the LME. It becomes the buyer to every seller and the seller to every buyer, so it guarantees performance of LME trades[^nickel-ca-12]. How clearing houses work is covered on the [Central Counterparties: JSCC, LCH, CME and Others](https://www.derivatives-compass.org/en/market-infrastructure/ccps/) page. Only members can trade directly on the LME. A member that has a direct contract with LME Clear is a [clearing member](https://www.derivatives-compass.org/en/glossary/clearing-member/), and clients that are not members trade through a member. Members must enter into contracts with their clients that follow the LME's rules[^nickel-ca-17]. The LME and LME Clear share ownership and have some directors in common, but they are separate legal entities with separate roles[^nickel-ca-16]. The LME decides whether to keep or cancel trades, and LME Clear decides how margin is calculated[^nickel-ca-62]. Rule 22 of the LME's trading rules provides that, when prices move sharply over a short period, the LME may temporarily halt or restrict trading and, if it considers it appropriate, cancel, vary, or correct trades[^nickel-ca-32]. This power derives from a requirement that the [Markets in Financial Instruments Directive II (MiFID II)](https://www.derivatives-compass.org/en/glossary/mifid-ii/) places on exchanges. In the court case, it was common ground that the rule should be read as allowing cancellation only in exceptional cases[^nickel-ca-38]. ## How margin calls work LME Clear bears the risk of default on both sides of a trade. Clearing members therefore post [margin](https://www.derivatives-compass.org/en/glossary/margin/), meaning funds or collateral that cover part of the amount LME Clear would be expected to owe if a member defaulted[^nickel-ca-26]. [Initial margin](https://www.derivatives-compass.org/en/glossary/initial-margin/) is required when a futures position is opened and is reviewed every day. [Variation margin](https://www.derivatives-compass.org/en/glossary/variation-margin/) can be called even during the day when price moves leave LME Clear's cover short[^nickel-ca-27]. The amount of a [margin call](https://www.derivatives-compass.org/en/glossary/margin-call/) is calculated using the latest market prices available at the time. Calls fall on every clearing member that holds a position in the metal, not only on those that traded that day, and they are calculated across all metals combined[^nickel-ca-27][^nickel-ca-28]. > **For operations and accounting: Payment deadlines for margin** > > Deadlines differ by the type of call. The first intraday call of the day is due by 09:00, later intraday calls within one hour, and the call from the end-of-day calculation by 09:00 the next day[^nickel-ca-27b]. If a clearing member fails to pay by the deadline, LME Clear must decide whether to declare it formally in default. The UK version of the European Market Infrastructure Regulation ([UK EMIR](https://www.derivatives-compass.org/en/glossary/emir/)) requires a clearing house to measure exposures in near real time. Margin must cover the exposure expected until a position is closed out, at a level that covers the losses arising in at least 99% of the changes in exposure. If a predefined threshold is exceeded, the clearing house must also call margin during the day[^nickel-ca-29]. When the price rises, calls grow for members with short [positions](https://www.derivatives-compass.org/en/glossary/position/). Consider a hypothetical example in which Company A holds a short position of 1,000 tonnes of nickel. The reference price is USD 30,000 per tonne. For simplicity, variation margin is called only for the change in mark-to-market gains and losses, and initial margin, fees, and interest are ignored. | Price (USD per tonne) | Mark-to-market gain or loss on the short position (USD million) | Variation margin for Company A | | --------------------: | --------------------------------------------------------------: | ------------------------------ | | 50,000 | −20 | Call of USD 20 million | | 100,000 | −70 | Call of USD 70 million | | 25,000 | +5 | Receipt of USD 5 million | If the price rises from USD 30,000 to USD 100,000, the loss is (100,000 − 30,000) × 1,000 tonnes = USD 70 million. If the price falls to USD 25,000, the gain is (30,000 − 25,000) × 1,000 tonnes = USD 5 million. Responding to calls is covered on the [Handling Margin Calls](https://www.derivatives-compass.org/en/liquidity-risk/margin-calls/) page. ## Timeline Russia invaded Ukraine in February 2022. In the days before March 7, 3-month nickel traded at about USD 27,000 to 29,000 per tonne. The LME took the view that the rise on March 4 could be explained by the situation resulting from the invasion[^nickel-ca-46]. A [price band](https://www.derivatives-compass.org/en/glossary/price-band/) is an LME mechanism that automatically rejects trades at prices outside a range. If a member contacts the LME's Trading Operations Team (TOT) to confirm that a trade outside the range is genuine and not a mistake, the trade can still be accepted[^nickel-ca-25]. | Date and time | Event | | --------------- | -------------------------------------------------------------------------------------------------------------------------- | | March 4 | The price rose 6.8%, and the intraday calls of about USD 2.6 billion were a record[^nickel-ca-46b] | | March 7 | The price rose 69% in one day, to just under USD 50,000[^nickel-ca-47] | | March 7 | Calls totaled about USD 7.05 billion, and three members failed to pay by the first deadline[^nickel-ca-48] | | March 8, 04:49 | The price reached about USD 60,000, and the LME's staff switched off the price bands[^nickel-ca-50] | | March 8, 06:08 | The price hit its high of USD 101,365[^nickel-ca-51] | | March 8, 07:24 | LME Clear circulated an estimate of the calls if it used the 07:00 price (about USD 80,000)[^nickel-ca-55] | | March 8, 07:30 | The LME's chief executive and others confirmed the suspension of trading[^nickel-ca-56] | | March 8, 08:15 | The LME suspended nickel trading in Notice 22/052[^nickel-ca-57] | | March 8, 09:00 | Senior executives of the LME and LME Clear discussed the treatment of the trades and the margin calculation[^nickel-ca-61] | | March 8, 12:05 | The LME announced the cancellation of trades from 00:00 in Notice 22/053[^nickel-ca-70] | | March 16, 08:00 | The nickel market reopened[^nickel-ca-72] | ### Why the LME chose cancellation The 07:24 estimate put the additional margin at about USD 19.75 billion in total, and at least five members were expected to be unable to pay by the 09:00 deadline[^nickel-ca-55]. The 09:00 meeting on March 8 considered whether to keep or cancel the trades together with the basis for calculating margin. The LME's chief executive had the authority to decide on the trades, and LME Clear's chief executive had the authority to decide on the margin calculation[^nickel-ca-61]. | Option | Description | Outcome of the discussion | | ------ | ----------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------- | | 1A | Keep the trades and calculate margin at the trade prices | Everyone who spoke found it unacceptable. Calls would have been about USD 19.75 billion | | 1B | Keep the trades and calculate margin at the March 7 closing price | Rejected because it would leave LME Clear under-collateralized. Additional calls would have been about USD 570 million | | 2 | Keep the trades and adjust the prices | Rejected because it would impose prices the parties had not agreed | | 3 | Cancel the trades from 00:00 on March 8 | Adopted | On Option 1A, everyone who spoke considered that the trades reflected prices in a disorderly market and were not meaningful prices. The chief executives of the LME and LME Clear thought that several members defaulting at once would be unprecedented[^nickel-ca-63]. On Option 1B, LME Clear's chief executive was concerned that LME Clear would be under-collateralized and that member defaults remained possible. Some attendees also felt it was inconsistent to keep the trades but not to collect margin at their prices[^nickel-ca-66]. On the scope of the cancellation, no one could identify when the market had moved from orderly to disorderly. The LME's chief executive used the close of trading on March 7, the last point at which the market was clearly orderly, as the cutoff. He recognized that those who had traded at high prices and made profits would be disadvantaged[^nickel-ca-68]. While the nickel market was closed, LME Clear calculated nickel margin at the March 7 closing price. The intraday calls on March 8 were paid without default, and no additional calls were needed during the closure. The market reopened once bank support for participants with short positions was in place and the LME's chief executive judged that orderly trading could resume[^nickel-ca-72]. ## Factors found by the independent review The LME commissioned Oliver Wyman and NERA UK to carry out an independent review and published the final report with a notice on January 10, 2023. The review covers the factors that affected conditions in the nickel market up to the decision to suspend on March 8. It excludes the decision-making and governance of the LME and LME Clear, which it left to separate reviews by the FCA and the [Bank of England](https://www.derivatives-compass.org/en/glossary/boe/)[^nickel-lme-scope]. It also does not address whether any trading was suspicious[^nickel-lme-p3]. The report analyzed the episode as a [short squeeze](https://www.derivatives-compass.org/en/glossary/short-squeeze/) in nickel, in which the LME nickel price rose by more than 270% over three trading days[^nickel-lme-p3]. The LME's notice groups the factors into the four below[^nickel-lme-9]. In the table, Class 2 refers to nickel products with a nickel content below 99.80%, such as nickel pig iron and ferronickel. The refined nickel behind the LME's futures is Class 1[^nickel-lme-gloss]. | Factor | What the report found | | --------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Build-up of large short positions | Positions split between the exchange and the [OTC market](https://www.derivatives-compass.org/en/glossary/otc-derivative/) were hard to see, and the position limits and monitoring levels did not prevent the build-up | | Sudden drop in volume available to trade (liquidity withdrawal) | Nickel was volatile, and few participants were willing to take the other side of trades | | Price acceleration and calls | The LME's mechanisms for limiting price moves did not work, and participants doubted the resilience of some members | | Sudden de-risking | Class 2 producers faced [basis risk](https://www.derivatives-compass.org/en/glossary/basis-risk/) in their [hedges](https://www.derivatives-compass.org/en/glossary/hedging/), and procedures for closing out positions had not been worked out | Class 2 producers may sell their products at local market prices. The LME price is for refined nickel, but producers had hedged at that price, so when the LME price rose sharply, a gap opened between that price and their selling prices[^nickel-lme-9]. The LME had dynamic and static price bands, but they did not stop the surge[^nickel-lme-p3]. According to the judgment, a later investigation suggested that the surge was caused by large short positions built up by several participants. One was a short position held in the OTC market by Tsingshan, a Chinese industrial user of nickel[^nickel-ca-71]. The FCA's Final Notice analyzes the interaction between very large OTC positions and the LME's market as the biggest driver of the price moves from March 4 to 8. OTC trades take place outside the LME's market, so the LME could not see those positions at the time[^nickel-fca-231]. The report gives three aims for its recommendations: to identify and prevent market distortions, to manage extreme events, and to restore confidence. Specific measures include LME-specific position limits, monitoring of large OTC positions, and stronger mechanisms for limiting price moves. The LME notes that the recommendations remain high-level and that implementation plans must be developed separately[^nickel-lme-13]. ## What changed afterward ### The outcome of the litigation Elliott claimed to have lost net profits of about USD 456 million because of the cancellation, and Jane Street about USD 15 million[^nickel-divct-3]. They asked for declarations that the decisions of the LME and LME Clear were unlawful, and also sought damages for breach of property rights under the Human Rights Act[^nickel-divct-4]. On November 29, 2023, the Divisional Court of the High Court (Administrative Court) held that the LME and LME Clear had acted lawfully and rejected both claims. Jane Street did not appeal[^nickel-ca-6]. On October 7, 2024, the Court of Appeal unanimously dismissed Elliott's appeal, with three judges agreeing[^nickel-ca-176]. The Court of Appeal made the following points. By law, the LME must have the power to cancel trades when prices move sharply over a short period, and Rule 22 of the trading rules was that power. Keeping the March 8 trades would have posed a real danger of a chain of failures across the international metals market (in the judgment's words, a "death spiral"). The LME and LME Clear were entitled to conclude that Option 1B would put LME Clear in breach of its regulatory obligations, and that left effectively no alternative to cancellation[^nickel-ca-174]. On whether Elliott's trades were property under the Human Rights Act, the Court of Appeal expressed the view that they were property, if it had to decide the point (the lower court had held that they were not). It held, however, that the right came with the power of cancellation attached in advance, so there was no interference, and that any interference would in any case be justified[^nickel-ca-160]. On January 28, 2025, the Supreme Court refused Elliott permission to appeal, finding that the application raised no arguable point of law[^nickel-uksc]. ### The response of the authorities On April 4, 2022, the FCA, the Prudential Regulation Authority ([PRA](https://www.derivatives-compass.org/en/glossary/pra/)), and the Bank of England issued a joint statement. The FCA would review how the LME managed the suspension and reopening, and the Bank of England would review the governance and risk management of LME Clear. Both said they would use skilled persons under section 166 of the Financial Services and Markets Act 2000. The LME acknowledged the benefit of adding independent directors[^nickel-boe-2022]. On March 3, 2023, the Bank of England said its review had found several deficiencies in the governance, management, and risk management of LME Clear. It required LME Clear to strengthen its governance, make its management and governance more independent, and improve its risk management. It planned to monitor progress using skilled persons[^nickel-boe-2023]. In its [Final Notice of March 19, 2025](https://www.derivatives-compass.org/en/timeline/#event-fca-fines-lme), the FCA imposed a penalty of GBP 9,245,900 on the LME. The LME agreed to resolve the matter early and received a 30% discount. Without the discount, the penalty would have been GBP 13,208,400[^nickel-fca-11]. The notice found that, from January 3, 2018 to March 8, 2022, the LME's systems and controls were not adequate to ensure orderly trading under conditions of severe market stress[^nickel-fca-52]. The notice lists the following facts. - The LME treated the price bands as a safeguard against erroneous orders and runaway algorithms. - The trading operations team had received no training or instructions on distinguishing a sharp move caused by intended trades from a sign of market disorder, or on escalating it to senior managers. - On March 8, the Hong Kong team covering overnight trading kept the price bands switched off for more than three hours, from 04:49 to 08:15. - Senior managers did not realize that the price bands had been switched off on the morning of March 8[^nickel-fca-2]. ### Changes at the LME To make large OTC positions visible, the LME introduced a rule requiring weekly reporting of OTC positions, together with daily price limits[^nickel-fca-31]. The action plan it published on March 30, 2023 includes improving how the daily price limits are set and strengthening real-time monitoring[^nickel-fca-32]. The nickel market resumed trading during Asian hours in March 2023[^nickel-fca-23]. In PS 25/1, the FCA addresses the risk that large OTC positions pose to exchange contracts[^nickel-fca-31]. [^nickel-fca-22]: Financial Conduct Authority (FCA), "[Final Notice: The London Metal Exchange (RIE)](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf)" (March 19, 2025), paragraph 2.2. [^nickel-ca-70]: Court of Appeal of England and Wales, "[Elliott Associates LP & Anor, R (on the application of) v The London Metal Exchange & Anor](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168)" (\[2024] EWCA Civ 1168, October 7, 2024), paragraphs 57 and 70 (quoting Notices 22/052 and 22/053). [^nickel-ca-72]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 72. [^nickel-fca-4105]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 4.105 (the original wording is "notional value of the cancelled trades"). [^nickel-ca-6]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 6 (the lower court's conclusion, and the absence of an appeal by Jane Street). The lower court's decision is the [judgment of the Divisional Court](https://caselaw.nationalarchives.gov.uk/ewhc/admin/2023/2969) (\[2023] EWHC 2969 (Admin), November 29, 2023). [^nickel-ca-176]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 176–178 (three judges agreeing on dismissal). [^nickel-fca-11]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraphs 1.1 and 1.2 (the penalty, the 30% discount, and GBP 13,208,400 without the discount). [^nickel-ca-10]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 10 and 11. [^nickel-ca-12]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 12 and 13 (LME Clear is an authorized central counterparty). [^nickel-ca-17]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 17–20 (contracts with clients under trading rule 2.6). [^nickel-ca-16]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 15 and 16. [^nickel-ca-62]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 62. [^nickel-ca-32]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 32 (quoting trading rule 22.1), and paragraphs 33 and 35. [^nickel-ca-38]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 38 (it was common ground that the rule should be read as including the "exceptional circumstances" requirement of Article 48(5) of MiFID II). [^nickel-ca-26]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 26. [^nickel-ca-27]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 27 (initial margin, variation margin, and the members that calls fall on). [^nickel-ca-28]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 28. [^nickel-ca-27b]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 27 (payment deadlines). The decision whether to declare a default is from the testimony of the LME's chief executive in paragraph 63. [^nickel-ca-29]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 29 and 30 (quoting Articles 40 and 41 of UK EMIR). [^nickel-ca-46]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 46. [^nickel-ca-46b]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 46 (opening price USD 27,080, closing price USD 28,919; the intraday calls were 40% above the previous record). [^nickel-ca-47]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 47 (about five times the next largest move in the past 20 years). [^nickel-ca-48]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 48 (about three times the previous business day; one member did not pay until the end of the day). [^nickel-ca-50]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 50. [^nickel-ca-51]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 51. [^nickel-ca-55]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 55 (the 07:00 price was about USD 80,000). [^nickel-ca-56]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 56. [^nickel-ca-57]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 57 (the notice gave "orderly market grounds" as the reason for the suspension). [^nickel-ca-61]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 61 and 62. [^nickel-ca-25]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 25. [^nickel-ca-63]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 63 and 64, and 67–69 (the reasons for rejecting Option 2; the USD 570 million estimate for Option 1B is in paragraph 69). [^nickel-ca-66]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 66. [^nickel-ca-68]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 68. [^nickel-lme-scope]: London Metal Exchange (LME), "[LME Group Response to Oliver Wyman Independent Review](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf)" (Notice 23/007, January 10, 2023), paragraphs 3 and 4. [^nickel-lme-p3]: Executive summary of the final report attached to [Notice 23/007](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf) (pages 3 and 4; PDF pages 6 and 7). [^nickel-lme-9]: [Notice 23/007](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf), paragraph 9 (factors a to d), combined with the description in the report's Executive summary. [^nickel-lme-gloss]: Glossary of the final report attached to [Notice 23/007](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf) ("Class 1 nickel", "Class 2 nickel", "Refined nickel"). [^nickel-ca-71]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraph 71 ("later investigation suggested"). [^nickel-lme-13]: [Notice 23/007](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf), paragraphs 8 and 13, and page 4 of the final report's Executive summary. [^nickel-divct-3]: [Divisional Court judgment](https://caselaw.nationalarchives.gov.uk/ewhc/admin/2023/2969), paragraph 3. [^nickel-divct-4]: [Divisional Court judgment](https://caselaw.nationalarchives.gov.uk/ewhc/admin/2023/2969), paragraph 4 (A1P1 is Article 1 of Protocol 1 to the European Convention on Human Rights). [^nickel-ca-174]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 126–128 and 174. [^nickel-ca-160]: [Court of Appeal judgment](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168), paragraphs 160, 169, 170, and 175. [^nickel-uksc]: UK Supreme Court, "[Permission to Appeal - January 2025](https://supremecourt.uk/news/permission-to-appeal-january-2025)", UKSC 2024/0153. [^nickel-boe-2022]: Bank of England, "[Joint statement from UK Financial Regulation Authorities on London Metal Exchange and LME Clear](https://www.bankofengland.co.uk/news/2022/april/joint-statement-from-uk-financial-regulation-authorities-on-london-metal-exchange-and-lme-clear)" (April 4, 2022). [^nickel-boe-2023]: Bank of England, "[Bank of England announces supervisory action on LME Clear](https://www.bankofengland.co.uk/news/2023/march/boe-announces-supervisory-action-on-lme-clear)" (March 3, 2023). [^nickel-fca-52]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 5.2 (REC 2.5.1, paragraph 3(1) and (2)(h)). [^nickel-fca-2]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraphs 2.7–2.8, 2.23–2.24, 2.28, and 2.30. [^nickel-fca-31]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 2.31 (weekly reporting in the LME's rules, and PS 25/1). The daily price limits are in paragraph 15 of [Notice 23/007](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf). [^nickel-fca-32]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 2.32. [^nickel-fca-231]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 2.31. [^nickel-fca-23]: [FCA Final Notice](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf), paragraph 2.3. ## Sources - [Final Notice: The London Metal Exchange (RIE)](https://www.fca.org.uk/publication/final-notices/london-metal-exchange-2025.pdf) — Financial Conduct Authority - [Elliott Associates LP & Anor, R (on the application of) v The London Metal Exchange & Anor \[2024\] EWCA Civ 1168](https://caselaw.nationalarchives.gov.uk/ewca/civ/2024/1168) — The National Archives - [Elliott Associates L.P. and other and Jane Street Global Trading v The London Metal Exchange and another \[2023\] EWHC 2969 (Admin)](https://caselaw.nationalarchives.gov.uk/ewhc/admin/2023/2969) — The National Archives - [LME Group Response to Oliver Wyman Independent Review](https://www.lme.com/-/media/Files/News/Notices/2023/01/GENERAL-UPDATES-23-007-LME-Group-Response-to-Oliver-Wyman-Independent-Review---Notice-and-Report.pdf) — London Metal Exchange and LME Clear - [Permission to Appeal - January 2025](https://supremecourt.uk/news/permission-to-appeal-january-2025) — UK Supreme Court - [Joint statement from UK Financial Regulation Authorities on London Metal Exchange and LME Clear](https://www.bankofengland.co.uk/news/2022/april/joint-statement-from-uk-financial-regulation-authorities-on-london-metal-exchange-and-lme-clear) — Bank of England - [Bank of England announces supervisory action on LME Clear](https://www.bankofengland.co.uk/news/2023/march/boe-announces-supervisory-action-on-lme-clear) — Bank of England