"The FCA expects asset managers and their staff to be scrupulous in identifying and managing conflicts and their risks."
The regulator has also fined Timothy Haywood, a former investment director and business unit head at the firm, £230,037.
The FCA's investigation found that GAM failed to manage conflicts of interest arising from three transactions, two of which were linked to Greensill Capital where Haywood was the investment manager making investment decisions.
Potential incentives were offered which would have provided benefits to GAM or its parent company and although these were not taken up, the FCA says they were "not dealt with properly" as conflicts of interest were not considered.
In addition, Haywood received gifts and entertainment, including travelling on a Greensill private aircraft, heightening the risk that he may have been incentivised to invest for personal interest.
Both GAM and Mr Haywood agreed to resolve the cases against them at an early stage of the FCA’s investigation and therefore qualified for a 30% discount.
Mark Steward, executive director of enforcement and market oversight at the FCA, said: "A robust framework, properly implemented and followed by all staff, is required to manage any conflicts of interest. GIML failed to do this. In an asset manager, this is vital in ensuring decisions are taken for the benefit of the investors. Mr Haywood’s disclosure failings are equally serious ones.
"The FCA expects asset managers and their staff to be scrupulous in identifying and managing conflicts and their risks. This case should send a clear warning to the market."
