Clearly that's based on the Mancini Al Jazira contract and I assume they're saying we falsified the accounts by keeping that £1.75m off the books. In the first full year of Mancini's tenure that was about 1% of our turnover, plus we lost nearly £200m.
Even in the event that the commission find that was a dodge, so what? It's completely insignificant. But why would we even try to hide £1.75m in the context of that scale of losses? It's hardly on the Enron scale of fraud.
I presume the PL rule they're citing however is the one where we have to give full details of the manager's remuneration, hence the charge. But they'd need to show that Mancini (and City) had no intention of him fulfilling that contract.