General Advice on Bets Against the Pound received in Correspondence with Commons Registrar

From: Commons Registrar
Sent: 07 January 2019 09:05
To: ONWURAH, Chi <>
Subject: RE: Bets against the pound.Advice

Dear Ms Onwurah

Thanks for this.

Under the Code of Conduct MPs are expected to base their conduct upon the public interest, to avoid conflict with their personal interest, and if a conflict arises, to resolve it at once and in favour of the public interest (paragraph 10).

I cannot comment on your three scenarios below, except to say that I agree that they would not necessarily be spelt out in the Register. As you say, it does not contain sufficient detail. However, registration is not the only way in which MPs have to disclose their interests.  MPs are however under a general duty to draw attention to an interest  on almost any occasion when someone else might reasonably consider it to influence their actions or words. There are exemptions for occasions when a declaration would unduly delay the proceedings of the House, for example if  an MP is asking a parliamentary question or a supplementary. You can find full guidance on declaring interests in this way, including the occasions when it is not required, in Chapter 2 of the Guide to the Rules.

I hope this helps. I am out of the office for most of the day but I will check my emails at lunchtime.

With best wishes

Heather Wood

Registrar of Members’ Financial Interests


From: ONWURAH, Chi
Sent: 05 January 2019 17:45
To: WOOD, Heather
Subject: Bets against the pound.

Dear Heather

There are reports of leading Brexiteer Members of Parliament standing to make significant personal gain by  ‘betting against the pound’ in relation to a No Deal Brexit fall in the value of the pound against the Euro and the Dollar.

I am looking to clarify whether this would have to be declared as a member’s interest in the detail necessary for others to understand what they were doing..

There are a number of ways in which a bet against the pound could be made. I specify three below, there may be more

  • Direct transactions in actual currency such as borrowing in pounds and buying foreign currencies with that borrowed money
  • Entering into contracts, for example futures contracts or derivatives contracts, that cause the individual to gain if the pound falls
  • Having a financial interest in an entity, for example a hedge fund, a unit trust, an exchange traded fund, or some other form of partnership, corporation, or trust, which is substantially engaged in either of the above two activities.

As MPs are soon to vote on the Brexit deal there is obviously a financial interest for any MP who engages in these ‘bets’.  I am not confident that these would be declared in a way that makes that financial interest clear. What is your view?


Chi Onwurah MP
Newcastle Central

Suite 25 7 Pink Lane

Newcastle upon Tyne


Tel +44191 232 5838

Twitter ChiOnwurah



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