UNITED STATES OF AMERICA Before the COMMODITY FUTURES TRADING COMMISSION. ) ) ) ) CFTC Docket No ) ) Respondents. )

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1 In the Matter f: UNITED STATES OF AMERICA Befre the COMMODITY FUTURES TRADING COMMISSION Barclays PLC, Bat'clays Bank PLC and Barclays Capital Inc., ) ) ) ) ) CFTC Dcket N ) ) Respndents. ) ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(c) AND 6(d) OF THE COMMODITY EXCHANGE ACT, AS AMENDED, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS I. The Cmmdity Futures Trading Cmmissin ("Cmmissin") has reasn t believe that Barclays PLC, Bat'clays Bank PLC ("Barclays Bank") and Barclays Capital Inc. ("Barclays Capital") (cllectively, "Respndents" r "Barclays") have vilated Sectins 6( c), 6( d) and 9(a)(2) f the Cmmdity Exchange Act (the "Act" r the "CEA"), 7 U.S.C. 9, l3b and 13(a)(2) (2006). Therefre, the Cmmissin deems it apprpriate and in the public interest that public administrative prceedings be, and hereby are, instituted t determine whether Respndents engaged in the vilatins set frth herein, and t determine whether any rder shall be issued impsing remedial sanctins. II. In anticipatin f the institutin f an administrative prceeding, Respndents have submitted an Offer f Settlement ("Offer"), which the Cmmissin has determined t accept. Withut admitting r denying the findings r cnclusins herein, except t the extent Respndents admit thse findings in any related actin against Barclays by, r any agreement with, the Department f Justice r any ther gvernmental agency r ffice, Respndents herein cnsent t the entry and acknwledge service f this Order Instituting Prceedings Pursuant t Sectins 6( c) and 6( d) f the Cmmdity Exchange Act, as Amended, Making Findings and Impsing Remedial Sanctins ("Order,,).1 Respndents cnsent t the entry f this Order and t the use f these findings in this prceeding and in any ther prceeding brught by the Cmmissin r t which the Cmmissin is a party; prvided, hwever, that Respndents d nt cnsent t the use f the Offer, r the findings r cnclusins in this Order, as the sle basis fr any ther prceeding brught by the Cmmissin, ther than in a prceeding in bankruptcy r t enfrce the terms f this Order. Nr d Respndents cnsent t the use f the Offer r this Order, r the findings in this Order cnsented t in the Offer, by any ther party in any ther prceeding.

2 III. The Cmmissin finds the fllwing: A. Summary Over a perid f several years, cmmencing in at least 2005, Barclays PLC, Barclays Banle and Barclays Capital, by and thrugh their agents, fficers and emplyees lcated in at least New Yrk, Lndn and Tky, repeatedly attempted t manipulate and made false, misleading r knwingly inaccurate submissins cncerning tw glbal benchmark interest rates, the British Banleers' Assciatin's ("BBA") Lndn Interbanle Offered Rate ("LIB OR") and the Eurpean Banldng Federatin's ("EBF") Eur Interbanle Offered Rate ("Euribr"). LIBOR and Euribr are leading shrt-term interest rate benchmarks intended t reflect the csts f bolt wing unsecured funds in certain interbanle markets. LIBOR and Euribr are critical t financial markets wrldwide. They are used t price a variety f glbal financial prducts, including U.S.-based swaps transactins and futures cntracts, as well as hme mrtgages and cmmercial and persnal cnsumer lans. Accrding t the Banle fr Internatinal Settlements ("BIS"), ver-the-cunter interest rate derivatives, such as swaps and Frward Rate Agreements ("FRAs"), cmprised ver $449 trillin in ntinal value at the end f 2009, and ver $500 trillin in ntinal value at the end f2011. Barclays Banle was, and is, a member f the panel f banles that submits rates fr the daily calculatin and glbal publicatin f varius currencies f LIB OR and Euribr. The rates submitted by panel banles shuld reflect r relate t the csts f boltwing unsecured funds in certain interbank markets. Barclays' vilative cnduct invlved multiple desks, traders, ffices and cultencies, including United States Dllar ("U.S. Dllar"), Sterling, Eur and Yen. The wrngful cnduct spanned frm at least 2005 thrugh at least 2009, and at times ccurred n an almst daily basis. Barclays' cnduct included the fllwing: (1) During the peridfrm at least mid-200s thrugh the fall f2007, and spradically thereafter int 2009, Barclays based its LIBOR submissins fr U.S. Dllar (and at limited times ther currencies) n the requests f Barclays' swaps traders, including frmer Barclays swaps traders, wh were attempting t affect the fficial published LIBOR, in rder t benefit Barclays' derivatives trading psitins; thse psitins included swaps and futures trading psitins; this same cnduct OCCUlTed with respect t Barclays' Euribr submissins fr the perid f at least mid-200s thrugh mid-2009 (see pp. 3-4, 7-11, 13-15, infra); (2) During the perid frm at least mid-200s thrugh at least mid-2008, certain Barclays Eur swaps traders, led by a frmer Barclays senir Eur swaps trader, crdinated with, and aided and abetted traders at celiain ther banles t influence the Euribr submissins f multiple banles, including Barclays, in rder t affect 2

3 the fficial published Euribr, and thereby benefit their respective derivatives trading psitins (see pp. 3-4, 15-18, infra); and (3) During the vlatile, glbal market cnditins f the financial crisis flate August 2007 thrugh early 2009 (the "financial crisis perid"), Barclays lwered its LIBOR submissins in rder t manage what it believed were inaccurate and negative public and media perceptins that Barclays had a liquidity prblem based in part n its high LIBOR submissins relative t the lw submissins f ther panel banks that Barclays believed were t lw given market cnditins. Pursuant t a directive by certain members f Barclays' senir management, Barclays submitted lwer rates fr U.S. Dllar LIB OR, and at limited times Yen and Sterling LIB OR, than what it had determined t be the apprpriate rates reflecting the csts f brrwing unsecured funds in the relevant markets (see pp. 4, 19-25, infra).' Barclays' lack f specific internal cntrls and prcedures cncerning its submissin prcesses fr LIBOR and Euribr and verall inadequate supervisin f trading desks allwed this cnduct t ccur. Specifically, during the perid frm at least mid-2005 thrugh the fall f2007, and spradically thereafter int 2009, interest rate swaps traders, primarily lcated in Barclays' New Yrk and Lndn ffices, regularly requested that the Barclays' emplyee(s) respnsible fr determining and submitting Barclays' daily LIBORs and Euribrs ("submitters") submit a particular rate r adjust their submitted rates higher r lwer in rder t affect the daily, fficial published LIBOR and Euribr. Barclays' swaps traders were imprperly attempting t benefit Barclays' derivatives trading psitins and the prfitability f their particular trading bks and desks. Barclays' swaps traders als facilitated frmer Barclays swaps traders' requests t alter LIBOR r Euribr submissins by passing alng the frmer traders' requests t the Barclays LIBOR r Euribr submitters as if they were their wn. The Barclays submitters rutinely based their LIBOR and Em'ibr submissins n the traders' requests in furtherance f the attempts t manipulate LIBOR and Euribr. The majrity f Barclays' vilative cnduct invlved U.S. Dllar LIBOR and Euribr, but als, at limited times, invlved Yen and Sterling LIBOR submissins. In additin, during the perid frm at least mid-2005 thrugh mid-2008, certain Barclays Eur swaps traders, led by a frmer Barclays senir Eur swaps trader, crdinated with and aided and abetted traders at certain ther banks in attempts t manipulate Euribr. The Barclays swaps traders crdinated with traders at ther banks n the rates t be submitted by their respective Euribr submitters in rder t benefit their banle's derivatives trading psitins. These Barclays Eur swaps traders agreed t ask, and did ask, the Barclays submitters fr rates that benefited the trading psitins f the traders at the ther banles. The Barclays swaps traders made these requests as if they were their wn requests and were t benefit Barclays' trading psitins. The submitters rutinely accmmdated thse requests. The Barclays Eur swaps traders als made similar requests t the traders at the therbanles in rder t benefit Barclays' derivatives trading psitins. 3

4 A banle's derivatives trading psitins r prfitability are nt legitimate r permissible factrs n which t base a banle's daily LIBOR and Euribr submissins. By basing its LIBOR and Euribr submissins n Barclays' derivatives traders' requests, and thereby n Barclays' derivatives trading psitins, Barclays' LIBOR submissins were nt cnsistent with the BBA's definitins and criteria fr LIBOR submissins. Instead, Barclays cnveyed false, misleading r knwingly inaccurate reprts that its submitted rates fr LIBOR and Euribr were based n and slely reflected the csts f bn-wing unsecured funds in the relevant interbanle markets. Accrdingly, Barclays regularly attempted t manipulate and knwingly delivered, r caused t be delivered, false, misleading r knwingly inaccurate reprts cncerning U.S. Dllar LIBOR and Euribr, and at times, Yen and Sterling LIBOR, which are all cmmdities in interstate cmmerce. During the financial crisis perid, Barclays believed that the market and media inaccurately perceived Barclays as having liquidity prblems in part because the rates submitted fr LIBOR by Barclays were significantly higher at times than the rates submitted by ther banles. Bat'clays cntended the ther banks' submissins were inapprpriately lw given the realities fthe market cnditins and lack f transactins ccurring in the interbanle markets. T manage public perceptins that its higher LIBOR submissins meant Barclays was a weaker institutin, Barclays' senir management directed the Barclays submitters t lwer Bat'clays' submissins in rder t be clser t the rates submitted by the ther banles, and thus, be a less nticeable utlier frm the rest f the banles. The Barclays submitters cmplied with the management directive by submitting artificially lwer rates than they wuld have therwise submitted and that were incnsistent with the definitin and criteria fr submitting LIBOR. As a result, Barclays did nt submit rates reflecting r relating t brrwing f unsecured funds in the relevant interbank markets. The management directive impacted at least Barclays' U.S. Dllar LIBOR submissins in multiple maturities ("tenrs") n a regular basis thrughut the financial crisis perid. The directive, n ccasin, als impacted Barclays' Sterling and Yen LIB OR submissins. Cncerns fr ne's reputatin r negative market r press reprts are nt legitimate r permissible factrs upn which a banle may base its daily LIBOR submissins. Accrdingly, during the financial crisis perid, Barclays, thrugh its submissins, knwingly delivered, r caused t be delivered, false, misleading r knwingly inaccurate reprts that affected r tended t affect LIBOR, a cmmdity in interstate cmmerce? *** In accepting Barclays' Offer, the Cmmissin recgnizes Respndents' significant cperatin during the Divisin f Enfrcement's investigatin f this matter, which included prviding imprtant infrmatin and analysis t the Divisin that helped the Divisin efficiently and effectively undeliake its investigatin. 2 While Barclays typically was ne f the highest submitters f the LIBOR panel banks during the financial crisis perid, Barclays' submissins, at times, were part fthe calculatin f the fficial published LIBOR. Hwever, the Cmmissin has nt fund evidence that Barclays lwered its LIBOR submissins in respnse t the management directive during the financial crisis perid with the intent t affect the fficial published LIBOR. 4

5 B. Respndents Barclays PLC is a British banking and financial services cmpany headquartered in the United Kingdm ("U.K."). It has peratins in ver 50 cuntries and territries including the United States. Barclays Bank PLC is a glbal banking and financial services cmpany based in the U.K. that is engaged in retail and cmmercial banking, credit cards, investment banking, wealth management and investment management services. It is whlly wned by Barclays PLC, and has ffices in N ew Yrk, New Yrk. Barclays Capital Inc. is a whlly wned subsidiary f Barclays PLC and engages in investment banking, wealth management and investment management services. It has been registered with the Cmmissin as a Futures Cmmissin Merchant since 1990, an apprved Exempt Freign Agent since 1992, and a Cmmdity Pl Operatr and Cmmdity Trading Advisr since It maintains a business address and an active trading ffice in New Yrk, New Yrk. C. Facts 1. Barclays. Thrugh the Acts f its Swaps Traders and Submitters. Made False LIBOR Reprts and Attempted t Manipulate LIBOR a. LIBOR and the BBA Fixing f LIB OR The BBA is a U.K. trade assciatin fr the u.k. banking and financial services sectr and is cmprised f member banks. The BBA is nt regulated. The BBA defines the term LIBOR and the criteria a panel bank is required t use in making its submissins, selects the banks fr the LIBOR panels fr each currency, and versees the prcess f LIB OR submissins and publicatin f LIB OR. The BBA als enters int licensing agreements with third parties, including parties in the U.S., t allw disseminatin f the LIBOR data. Thmsn Reuters is the BBA's agent fr the cllectin, calculatin and publicatin f the daily LIBORs. The BBA represents that LIBOR is intended t be a barmeter t measure strain in mney markets, that it ften is a gauge f the market's expectatin f future central banle interest rates, and that apprximately $350 trillin f ntinal swaps and $10 trillin f lans are indexed t LIBOR. LIBOR als is the basis fr settlement f interest rate futures and ptins cntracts n many f the wrld's majr futures and ptins exchanges, including the three-mnth and nemnth Eurdllar cntracts n the Chicag Mercantile Exchange ("CME"). Measured by the ntinal value f pen interest, the CME Eurdllar cntract is the mst liquid and largest ntinal futures cntract traded n the CME and in the wrld. The ttal traded vlume f the CME Eurdllar cntract had a ntinal value f ver $437 trillin in 2009 and $564 trillin in It settles based n the three-mnth U.S. Dllar LIB OR published n the Mnday befre 5

6 the last trading day f the cntract mnth? Mrever, LIBOR is fundamentally critical t financial markets and has an enrmusly widespread impact n glbal markets and cnsumers. LIBOR als affects businesses seeking credit, cnsumers btaining mrtgages r persnal lans, and market participants transacting in numerus ther financial cntracts in the U.S. and abrad that are based n the benchmark interest rates. Daily LIBORs are issued fr ten currencies with fifteen tenrs ranging frm vemight thrugh twelve mnths. Accrding t the BBA, LIB OR "is based n ffered inter-bank depsit rates cntributed in accrdance with the Instructins t BBA LIBOR Cntributr banks." The BBA requires that "[a]n individual BBA LIB OR Cntributr Panel Banle will cntribute the rate at which it culd brrw funds, were it t d s by asking fr and then accepting inter-bank ffers in reasnable market size just prir t [11 :00 a.m. Lndn time].,,4 By its definitin, LIBOR requires the submitting panel banks t determine the rates at which they can btain funds in the Lndn interbank market. The definitin f LIB OR des nt permit cnsideratin f factrs unrelated t the csts fboltowing unsecured funds. Every business day shrtly befre 11 :00 a.m. Lndn time, the banks n the LIB OR panels submit their rates t Thmsn Reuters. On behalf f the BBA, Thmsn Reuters cmpiles a day's LIBOR fr each currency and tenr by excluding the tp and bttm quartile f rates and averaging the remaining eight rates. That average rate becmes the fficial BBA daily LIBOR (the "LIBOR fixing"). The BBA then makes public the daily LIB OR fixing fr each currency and tenr, as well as the daily submissins f each panel banle, thrugh Thmsn Reuters and the ther data vendrs licensed by the BBA. This infrmatin is made available and relied upn thrughut the wrld, including in the United States. b. Barclays' Mney Market Desk and its LIBOR Submissin Prcess Bat'clays Banle is a member f the BBA and is ne f the panel banles that submit rates fr the determinatin f LIB OR fr U.S. Dllar, Sterling, Eur, Yen and ther currencies. s During the times relevant herein, a Bat'clays Banle emplyee sat n the Steering Cmmittee and Freign Currency and Mney Market ("FX & MM") Cmmittee f the BBA. The FX & MM Cmmittee has respnsibility fr the peratins and management f LIB OR. The Steering Cmmittee was respnsible fr the annual review f the LIBOR definitin and f the cntributrs t the BBA LIBOR panels t determine whether they were still apprpriate t remain n the panels. The CME has a licensing agreement with the BBA that "permits the [CME] t use BBA LIBOR as the basis fr settling Three-Mnth Eurdllar futures cntracts and t refer t BBA LIBOR in cnnectin with creating, marketing, trading, clearing, settling and prmting Three-Mnth Eurdllar futures cntracts." CME Rulebk, Chapter 452, Three-Mnth Eurdllar Futures. The CME als has the same licensing agreement t use BBA LIBOR as the basis fr settling CME ne-mnth Eurdllar cntracts. 4 This definitin f LIB OR has been used by the BBA frm 1998 t the present. In June 2008, in the wake f press questining the underpinnings f LIB OR, the BBA prvided additinal infrmatin cncerning the definitin that it said prvided mre guidance. 5 Barclays Bank als was, and is, n the panels fr making LIBOR submissins fr Swiss franc, Canadian dllar, Australian dllar, Swedish krna and Danish krne. 6

7 Barclays Bank makes its daily submissins thrugh Barclays' Lndn Nn-Sterling Liquidity Management Desk (the "Lndn Mney Market Desk"). The primary respnsibility f the Lndn Mney Market Desk, and the LIBOR submitters n the desk, is t manage Barclays' liquidity psitin and ensure that Bat'clays is fully funded each day in all currencies, including u.s. Dllar. 6 Until apprximately the end f2008, the Lndn Mney Market Desk maintained its wn trading bk with prfit and lss targets. Thrughut the perids relevant herein, Barclays regarded its senir and primary U.S. Dllar LIBOR submitter as the expert n the U.S. Dllar mney markets. This submitter had ver 25 years f experience in the U.S. Dllar mney markets and had been a lng-standing emplyee f Barclays. He had been determining Barclays' daily U.S. Dllar LIBOR submissins since Anther mney market trader assisted the senir U.S. Dllar LIBOR submitter, and at times determined Bat'clays' U.S. Dllar LIB OR submissins. Bat'clays' U.S. Dllar LIB OR submitters were the persns best situated t understand Barclays' ability t brrw funds in the Lndn interbank market, and therefre t determine the apprpriate U.S. Dllar LIBOR submissins t make n behalf f Barclays. Bat'clays' U.S. Dllar LIBOR submitters based their daily submissins n certain market infrmatin, including, but nt limited t, the fllwing: (1) cash transactins that had taken place in the Lndn U.S. Dllar mney market and Bat'clays' ability t btain funds in reasnable size at thse rates; (2) market infrmatin btained frm Lndn interdealer brkers, i.e., vice brkers, vernight financial news, and/r internal Barclays research dcuments; (3) central banks' decisins with respect t interest rates; (4) prir LIBOR submissins by Bat'clays and ther panel banks; and (5) expectatins f Federal Open Market Cmmittee decisins regarding interest rates. After cnsidering these factrs, the Barclays U.S. Dllar LIBOR submitters determined a rate figure fr each tenr and entered it int a spreadsheet fr submissin. Bat'clays did nt have specific internal cntrls r prcedures, written r therwise, regarding hw LIBOR submissins shuld be determined r mnitred. Bat'clays als did nt require dcumentatin f the submitters' LIBOR determinatins. c. Barclays Attempted t Manipulate LIBOR t Benefit Derivatives Trading Psitins Frm at least mid-2005 thrugh the fall f2007, and spradically thereafter int 2009, Barclays, thrugh the acts f its swaps traders and submitters, attempted t manipulate U.S. 6 Because mst f the LIBOR cnduct at issue invlves Barclays' U.S. Dllar LIBOR submissins, the factual findings fcus n U.S. Dllar LIBOR. As nted, hwever, the Cmmissin finds vilative cnduct at limited times with respect t Barclays ' Yen and Sterling LIBOR submissins. 7 Bat'clays' senir U.S. Dllar LIBOR submitter als had versight respnsibility fr the submissin f Barclays' Yen LIBOR which was handled daily by ther submitters. 7

8 Dllar LIBOR, and n ccasin, Yen and Sterling LIBORs, fr certain tenrs. Barclays' attempts t manipulate u.s. Dllar LIBOR ccurred at times n a daily basis. Multiple interest rate swaps traders lcated in Bat'Clays' New Yrk, Lndn and Tky ffices asked Bat'clays' LIBOR submitters t make certain LIBOR submissins in rder t affect the fficial BBA LIBOR fixings fr celiain tenrs, thereby benefitting their respective derivatives trading psitins and either increasing their prfits r minimizing their lsses. 8 The vast majrity f these requests came frm traders n Barclays' New Yrk Interest Rate Swaps Desk ("NY Swaps Desk") lcated in New Yrk and Lndn and invlved U.S. Dllar LIBOR. 9 The NY Swaps Desk trades in a variety f prducts, including interest rate swaps, 10 FRAs, Treasury bnds, and Treasury futures, as well as the CME ne-mnth and three-mnth Eurdllar futures and ptins cntracts. The interest rate swaps traded by the NY Swaps Desk were generally tied t varius tenrs f U.S. Dllar LIBOR. Barclays acted as cunterparty t clients in many interest rate swaps transactins. The derivatives instruments traded by the NY Swaps Desk were used t hedge the desk's interest rate risk and als t generate a prfit fr the desk. Senir traders n the NY Swaps Desk instructed several ther swaps traders t make the requests f the LIB OR submitters n Barclays' Lndn Mney Market Desk fr certain LIBOR submissins in rder t mve their LIBOR submissins in a directin t benefit the desk's derivatives trading psitins. 11 The traders' cnduct was cmmn and pervasive, and knwn by ther traders and trading desk managers lcated near the interest rate swaps desk, bth in New Yrk and Lndn. Nne f the traders attempted t cnceal the requests frm supervisrs at Barclays during the entire perid that the activity ccurred. In fact, n ccasin, the traders discussed their requests with trading desk managers. The swaps traders made the requests in persn, via , and thrugh electrnic "chats" ver an instant messaging system. On a few ccasins, sme swaps traders even made entries in electrnic calendars t remind themselves what requests t make f Barclays' LIBOR submitters the next day. Fr a time, a trader sitting in Lndn facilitated many f the requests n behalf f the New Yrk swaps traders by frwarding the requests in persn r by t the submitters. 8 Prir t the financial crisis perid, LIBOR generally was a stable rate with minute fluctuatins. In additin, the range amng the panel banks submissins was narrw, and panel banks frequently submitted the same rates. 9 There were several requests t alter Yen LIBOR frm swaps traders in Barclays' Tky ffice and at least ne request t alter Sterling LIBOR frm a Barclays trader in Barclays' Singapre ffice. 10 An interest rate swap generally exchanges a fixed payment fr a flating payment, wherein ne party t a swap wuld pay a fixed rate and the ther party t the swap wuld pay a flating rate, which is generally tied t three-mnth LIBOR. 11 Almst all f the traders invlved in this cnduct are n lnger emplyed at Barclays. 8

9 The swaps traders expected that the LIBOR submitters wuld take their requests int accunt when detelmining their LIB OR submissins. 12 Additinally, certain Barclays swaps traders received external requests t alter Barclays' U.S. Dllar LIB OR submissins frm frmer Barclays swaps traders wh had left Barclays and nw were emplyed by ther financial institutins. These frmer Barclays emplyees made the requests t benefit their derivatives trading psitins, and expected that nt nly wuld these requests be frwarded t the LIBOR submitters, but that Bat'clays' LIBOR submitters wuld take their requests int accunt when making their LIB OR submissins. These requests were made typically by r by instant message. The swaps traders' requests, whether internal r external, typically cncerned the nemnth and three-mnth U.S. Dllar LIBOR submissins. The traders' requests als included either a specific rate t be submitted r the directin, higher r lwer, that they wanted Barclays' LIBOR submissin t mve. Smetimes, the traders asked the submitters t try t have Barclays excluded ("kicked ut" r "kncked ut") frm the LIBOR calculatin by being in the tp r bttm quartile, in an attempt t influence the fficial LIBOR fixing. Smetimes the requests cvered several days r even weeks f submissins at a time. The fllwing are just sme examples f the numerus trader requests ver the years in questin: 1) "WE HAVE TO GET KICKED OUT OF THE FIXINGS TOMORROW!! We need a 4.17 fix in 1m (lw fix) We need a 4.41 fix in 3m (high fix)" (Nvember 22, 2005, Senir Trader in New Yrk t Trader in Lndn); 2) "Yu need t take a clse lk at the reset ladder. We need 3M t stay lw fr the next 3 sets and then I think that we will be cmpletely ut f ur 3M psitin. Then its n. [Submitter] has t g crazy with raising 3M Libr." (February 1,2006, Trader in New Yrk t Trader in Lndn); 3) "Yur annying clleague again... Wuld lve t get a high 1m Als if pss a lw 3m... ifpss... thanks" (February 3, 2006, Trader in Lndn t Submitter); 4) "This is the [bk's] risk. We need lw 1M and 3M libr. PIs ask [submitter] t get 1M set t 82. That wuld help a lt" (March 27,2006, Trader in New Yrk t Trader in Lndn); 5) "We have anther big fixing tm[rrw] and with the market mve I was hping we culd set the 1M and 3M Librs as high as pssible" (May 31, 2006, Trader in New Yrk t Submitter); 12 Apprpriate daily supervisin f the desk by the supervisrs, as well as peridic review f the cmmunicatins, shuld have discvered the cnduct. Hwever, Barclays lacked specific internal cntrls and prcedures that wuld have enabled Barclays' management r cmpliance t discver this cnduct. 9

10 6) "Hi Guys, We gt a big psitin in 3m libr fr the next 3 days. Can we please keep the lib r fixing at 5.39 fr the next few days. It wuld really help. We d nt want it t fix any higher than that. Tks a lt." (September 13, 2006, Senir Trader in New Yrk t Submitter); 7) "Fr Mnday we are very lng 3m cash here in NY and wuld like the setting t be set as lw as pssible... thanks" ( December 14, 2006, Trader in New Yrk t Submitter); and 8) "PIs. g fr 5.36 Libr again tmrrw, very lng and wuld be hurt by a higher setting... thanks." (May 23, 2007, Trader in New Yrk t Submitter). The LIBOR submitters regularly cnsidered the swaps traders' requests when determining and making Bm'clays' U.S. Dllar LIBOR submissins. T accmmdate the swaps traders, the submitters mved Barclays' U.S. Dllar LIBOR submissins by ne r mre basis pints in the directin requested by swaps traders, r submitted a specific rate depending n the particulars f the swaps traders' requests. The submitters frequently respnded affirmatively t the traders that they wuld accmmdate the requests, ften by saying "sure," "will d my best," r similar wrding. In additin, the submitters in a cuple f instances made entries in their wn electrnic calendars t remind themselves what rate t submit in rder t accmmdate a request made by swaps traders the previus day. Examples f the many instances where the submitters agreed t make the false submissins and attempted t manipulate the rate are: 1) "Am ging 13. think market will g ~." (Nvember 14,2005, Submitter's respnse t a swaps trader request fr a very high ne-mnth U.S. Dllar LIBOR submissin, preferably a submissin f "13+"); 2) "[Senir Trader] wes me!" (February 7, 2006, Submitter's respnse when swaps trader called him a "superstar" fr mving Barclays' U.S. Dllar LIBOR submissin up a basis pint mre than the submitter wanted and fr making a submissin with the intent t get "kicked ut"); 3) "Ging 58 [in 1 mnth] and 73 [in 3 mnth] and fully expecting t be kncked ut." (February 8, 2006, Submitter's respnse t a swaps trader request fr high ne-mnth and three-mnth LIBOR submissins); 4) "Fr yu... anything. I am ging t g 78 and It is difficult t g lwer than that in threes. lking at where cash is trading. In fact, if yu did nt want a lw ne I wuld have gne 93 at least." (March 16, 2006, Submitter's respnse t swaps trader's request fr a high ne-mnth and lw three-mnth U.S. Dllar LIBOR); 5) "Always happy t help, leave it with me, Sir." (March 20,2006, Submitter's respnse t a request); 6) "Dne... fr yu big by... " (April 7, 2006, Submitter's respnse t swaps trader requests fr lw ne-mnth and three-mnth U.S. Dllar LIBOR); and 10

11 7) "Set it at against a cnsensus f 34."(March 5, 2007, Submitter's respnse t swaps trader request fr high three-mnth U.S. Dllar LIBOR). Barclays' submitters knew it was imprper t cnsider swaps traders' derivatives trading psitins in determining the bank's LIBOR submissins. A bank's financial derivatives trading psitins are nt legitimate r permissible factrs n which t base a bank's daily LIBOR submissins. By basing its U.S. Dllar LIB OR submissins n Barclays' derivatives traders' requests, and thereby n Barclays' derivatives trading psitins, Barclays' LIB OR submissins were nt cnsistent with the BBA's definitins and criteria fr LIBOR submissins. Instead, Barclays cnveyed false, misleading r knwingly inaccurate reprts that its submitted rates fr LIBOR were based n and slely reflected its csts f brrwing unsecured funds in the Lndn interbank mney market. Accrdingly, Barclays regularly attempted t manipulate and knwingly delivered false, misleading r knwingly inaccurate repolis cncerning U.S. Dllar LIBOR, and at times, Yen and Sterling LIB OR, which are all cmmdities in interstate cmmerce Barclays Attempted t Manipulate Euribr, Made False Euribr Reprts and Crdinated with Other Banks in its Attempts t Manipulate Euribr Barclays, thrugh its swaps traders and submitters, als attempted t manipulate Euribr thrugh internal requests by traders, which were accmmdated by Barclays' submitters. The Eur swaps traders' at times crdinated their requests with swaps traders at certain ther banks. The requests were made in rder t benefit Barclays' derivatives trading psitins and the derivatives trading psitins f the ther individual institutins invlved. a. Euribr and the EBF Fixing f Euribr The EBF is an unregulated nn-prfit assciatin f the Eurpean banking sectr based in Brussels, Belgium. Amng ther functins, the EBF versees the publicatin f Euribr, the predminant mney market reference interest rate fr the Eur currency. Euribr is used internatinally in derivatives cntracts, including interest rate swaps and futures cntracts. 14 Accrding t the BIS, ver-the-cunter interest rate derivatives, such as swaps and FRAs, cmprised cntracts wrth ver $175 trillin in ntinal value referenced t Eur rates at the end f2009, and ver $220 trillin in ntinal value at the end f2011. Euribr is defined as the rate "at which Eur interbank term depsits are ffered by ne prime bank t anther prime bank" within the Ecnmic and Mnetary Unin f the Eurpean Unin ("EMU") at 11 :00 a.m. Central Eurpean Time ("CET") daily. Euribr is determined using submissins frm a panel f ver 40 mstly Eurpean banks cnsidered t be the mst active in the Eur zne with the highest vlume f business in the EMU. Accrding t the EBF instructins, panel banks "must qute the required eur rates t the best f their knwledge." 13 As previusly nted, there were sme similar requests in this same perid that the submitters make celiain submissins invlving Yen and Sterling LIBOR. 14 In Octber 2011, the CME launched the Euribr Futures cntract, which settles based n the threemnth Euribr. 11

12 The panel banks are t bserve the market and base their submissins n where the Eur is trading in that market. By its definitin, Euribr requires the submitting panel banks t determine the rates at which funds may be btained in the Eur interbank mney market. The definitin f Euribr des nt permit cnsideratin f factrs unrelated t the csts fboltowing unsecured funds. Euribr is fixed every business day fr fifteen tenrs, ranging frm ne week t twelve mnths. Like the BBA panel banks, the Euribr panel banks submit their rates electrnically t Thmsn Reuters, which manages the fficial Euribr prcess by cllecting the submitted rates frm the cntributing banks, calculating the rate, and then releasing it fr publicatin just befre nn CET. Thmsn Reuters cmputes that day's published Euribr by eliminating the highest and lwest fifteen percent f submissins cllected, and averaging the remaining submissins. That average rate becmes the fficial daily EBF Euribr (the "Euribr fixing"). On behalf f EBF, Thmsn Reuters then issues the Euribr fixing and the submissins f each panel bank t its subscribers and ther data vendrs. Thrugh these licensing agreements with third parties, such as Thmsn Reuters, EBF disseminates the infrmatin thrughut the wrld, including in the United States. b. Barclays' Mney Market Desk and its Euribr Submissin Prcess Barclays' Lndn Mney Market Desk was als respnsible fr Barclays Banle's daily Euribr submissins. Thrughut the perids relevant herein, Barclays regarded its primary and senir Euribr submitter as the expert n the Eur mney markets. Barclays' senir Euribr submitter had ver 20 years f experience in the Lndn mney markets and had been with Barclays fr ver 35 years. He had been determining Barclays' daily Euribr submissins since Tw ther mney market traders assisted the senir Euribr submitter and als determined Barclays' Euribr submissins. Barclays' Euribr submitters were the persns best situated t understand Bat'clays' ability t boltow unsecured funds in the Eur interbanle market, and therefre, t determine the csts, real and perceived, f bolt wing unsecured funds and the apprpriate Euribr submissins t make n behalf f Barclays Banle In determining their daily Euribr submissin, Barclays' Euribr submitters cnsidered Bat'Clays' Eur transactins in the varius tenrs applicable t Em'ibr and infrmatin received frm market intermediaries, such as vice brkers, indicating the prices at which the Eur was trading. Bat'clays' Euribr submitters made their submissin t Thmsn Reuters shrtly befre 11:00 a.m. CET. Barclays did nt have specific internal cntrls r prcedures, written r therwise, regarding hw Euribr submissins shuld be determined r mnitred. Barclays als did nt require dcumentatin f the submitters' Euribr determinatins. 12

13 c. Barclays Swaps Traders Requested Certain Euribr Submissins t Benefit Derivatives Trading Psitins During the perid frm at least mid-2005 thrugh mid-2009, Eur interest rate swaps traders lcated in Barclays' Lndn ffice made requests t Barclays' Euribr submitters fr higher r lwer Euribr submissins with the purpse f affecting the fficial Euribr fixing. IS Certain f these traders, in particular ne frmer senir Eur swaps trader, als regularly cntacted r were cntacted by traders at certain ther banks n the EBF Euribr panel t crdinate the rates each trader wuld request f their wn respective submitters. In making these requests, the traders attempted t manipulate the fficial EBF Euribr fixings fr varius tenrs in rder t benefit the traders' Eur derivatives trading psitins and thereby increase Barclays' prfits r minimize its lsses. Bat'clays' Eur interest rate swaps desk was primarily respnsible fr trading Eurdenminated interest rate swaps. The desk als traded EONIA 16 -based swaps, Eur-based FRAs, and Eur-based futures and ptins. The traders held Eur-based interest rate swaps psitins generally tied t varius tenrs f the EBF Euribr. The traders hedged thse psitins with ther derivatives instruments. Just as the NY Swaps Desk benefitted frm mvements in the LIB OR fixing, the traders' derivatives psitins benefited ifthe fficial EBF Euribr fixing mved in a certain directin depending n the characteristics f particular transactins. The traders' derivatives psitins were mst affected by the Euribr fixing in the ne-mnth, threemnth, and six-mnth tenrs. These were the tenrs in which the traders mst frequently requested a high r lw submissin by the Euribr submitters. i. Imprper Cmmunicatins Between Barclays' Traders and Barclays' Submitters Just as the NY Swaps Desk penly discussed requests t LIBOR submitters, Barclays' Eur swaps traders' requests t Barclays' Euribr submitters t change their submissins t benefit the traders' derivatives trading psitins were an pen, cmmn and pervasive practice n the desk. Multiple traders engaged in this cnduct, and n attempt was made by any f the traders t cnceal the requests frm sufervisrs at Barclays during the mre than fur-year perid in which the activity cculted. 1 In fact, traders wuld ften shut acrss the trading desk t fellw traders t cnfirm there were n cnflicting requests befre they sent their requests t the Euribr submitters, and, n ccasin, the traders discussed their requests with trading desk managers. 15 The Bur swaps traders and Buribr submitters are different individuals than the u.s. Dllar swaps traders and LIBOR submitters discussed abve. 16 BONIA, 01' the Bur OverNight Index Average, is BBF's vernight reference rate fr the Bur. It is a weighted average f all vernight unsecured lending transactins undertaken by panel banks in the Bur interbank market. 17 Apprpriate daily supervisin f the desk by the supervisrs as well as peridic review f the cmmunicatins shuld have discvered the cnduct. Hwever, Barclays lacked specific internal cntrls and prcedures that wuld have enabled Barclays' management r cmpliance t discver this cnduct. 13

14 After determining hw mves in EBF Euribr wuld affect the desk's prfitability, Barclays' Eur swaps traders cntacted the Euribr submitters, including via and thrugh electrnic "chats" ver an instant messaging system, t request that the submissins be mved either higher r lwer in a particular tenr. On a few ccasins, ne swaps trader made entries in electrnic calendars t remind himself what requests t make f Barclays' Euribr submitters the next day. Barclays' Euribr submitters accmmdated the requests, frequently expressly respnding in the affirmative t the traders' requests. The Eur swaps traders expected that the Euribr submitters wuld take their requests int accunt when determining their Euribr submissins. Additinally, ne frmer Barclays' senir Eur swaps trader n ccasin sent requests t alter Barclays' Euribr submissins t his frmer fellw traders after he had left Barclays and was emplyed by ther financial institutins. He made the requests t benefit his derivatives trading psitins. These requests were made at a minimum by r by instant message. The fllwing are just sme f the numerus examples f the cmmunicatins between the traders and submitters: 1) June 1,2006: Senir Eur Swaps Trader: "Hi [Euribr Submitter], is it t late t ask fr a lw 3m?" Euribr Submitter: "Just abut t put them in... s n." 2) September 7, 2006: Senir Eur Swaps Trader: "i have a huge 1m fixing tday and it wuld really help t have a lw 1m tx a lt." Euribr Submitter: "I'll d my best." Senir Eur Swaps Trader: "because I am aware sme ther banle need a very high ne....if yu culd push it very lw it wuld help. I have 50bn fixing." 3) Octber 13, 2006: Senir Eur Swaps Trader: "I have a huge fixing n Mnday... smething like 30bn 1m fixing... and I wuld like it t be very very very high... Can yu d smething t help? I knw a big clearer will be against us... and dn't want t lse mney n that ne." Euribr Submitter frwarded the request t anther Euribr submitter, advising: "We always try and d ur best t help ut.... " 14

15 Senir Euribr Submitter t Senir Eur Swaps Trader: "By the way [Euribr Submitter] tells me that it wuld be gd t see a high lmth fix n Mnday, we will pay fr sme cash that mrning s hpefully that will help." 4) January 12,2007: Senir Eur Swaps Trader: "hi [Euribr Submitter]. we need a lw 1m in the cming days if u can... " Senir Euribr Submitter: "hi [Senir Eur Swaps Trader], we will keep the 1mth lw fr a few days." 5) April 2, 2007: Eur Swaps Trader: "hell [Senir Euribr Submitter], culd yu please put in a high 6 mnth euribr tday?" Senir Euribr Submitter: "will d." 6) July 29,2008: ii. Eur Swaps Trader t Senir Eur Swaps Trader: "I was discussing the strategy [t get a high fixing] with [Senir Euribr Submitter] earlier this mrning - tday he will stay bid in the mkt and put a high fixing but withut lifting any ffer, and then he will be really paying up fr cash tmrrw and Thursday which is when the big psitive resets are." Barclays' Crdinatin and Cmmunicatins with Certain Other Banks t Attempt t Manipulate Euribr During the perid frm at least mid-2005 thrugh mid-2008, celiain Barclays Eur swaps traders, led by the same frmer Barclays' senir Eur swaps trader, crdinated with traders at celiain ther panel banks t have their respective Euribr submitters make certain Euribr submissins in rder t affect the fficial EBF Euribr fixing. These requests t and amng the traders were made t benefit the traders' respective derivatives trading psitins and either maximize their prfits r minimize their lsses. The frmer Barclays senir Eur swaps trader, while still emplyed by Barclays, spke daily with traders at certain panel banks cncerning their respective derivatives psitins in rder t determine hw t change the fficial EBF Euribr fixing in a manner that benefitted their derivatives psitins.i 8 In these cnversatins, the traders agreed t cntact their respective Euribr submitters t request the agreed-upn Euribr submissin. The Barclays senir Eur swaps trader als received at times requests fr certain Euribr submissins frm traders at the ther banks, which he then made f the Barclays Euribr submitters as if the requests were his 18 When he was ut f the ffice, the Bat'clays senir Eur swaps trader directed ther traders n the desk t cntact the traders at the ther banks n his behalf. 15

16 wn, at times blind carbn cpying the external trader n his s t Barclays' Euribr submitters. By such cnduct, the Barclays Eur Traders were attempting t manipulate Euribr and aiding and abetting the attempts t manipulate Euribr by ther banks. The fllwing are examples f the cmmunicatins amng the Barclays Senir Eul'O Trader, Barclays' Euribr submitters and traders at ther banks: 1) August 14, 2006: Trader at Bank A asked Barclays' Senir Eul'O Swaps Trader t request a lw ne mnth and high three mnth and six mnth Euribr. Barclays' Senir Eur Swaps Trader agreed t d s and prmised t cntact the trader at Banle B t make the same request. Barclays' Senir Eur Swaps Trader ed the Barclays Senir Euribr Submitter: "We have sme big fixings tday. Is it pssible t have a very lw 1m and high 3m and 6m? Thx a lt fr yur help." Barclays' Senir Euribr Submitter respnded: "Sure, will d." 2) Nvember 10,2006: Trader at Banle A asked Barclays' Senir Eul'O Swaps Trader t request a lw ne mnth Euribr setting at Barclays and at Banle B. Barclays' Senir Eur Swaps Trader made the request fthe trader at Banle B. Barclays' Senir Eur Swaps Trader ed the request t the Barclays Senir, Euribr Submitter: "hi [Senir Euribr Submitter]. I knw yu can help. On Mnday we have a huge fixing n the 1m and we wuld like it t be lw if pssible. Tx fr yur kind help." Barclays' Senir Euribr Submitter replied: "f curse we will put in a lw fixing." 3) Nvember 13, 2006: Barclays' Senir Eur Swaps Trader discussed the need fr lw ne mnth Euribr with traders at Banle A and Banle B, and cntacted a trader at Banle C. Barclays' Senir Eul'O Swaps Trader then reminded Barclays' Senir Euribr Submitter f his request frm Friday: "hi [Senir Euribr Submitter]. Srry t be a pain but just t remind yu the impoliance f a lw fixing fr us tday." Barclays' Senir Euribr Submitter replied: "n prblem, I had nt frgttn. The [vice] brkers are ging fr 3.372, we will put in 36 fr ur cntributin; " 16

17 Barclays' Senir Eur Swaps Trader's respnded: "I lve yu." 4) December 5, 2006: Barclays' Senir Eur Swaps Trader requested that traders at Banks A, Band C have their Euribr submitters make a high six mnth Euribr submissin. When the trader at Bank C stated that he needed the same submissin, Barclays' Senir Eur Swaps Trader agreed t make the request f the Barclays Euribr submitters. Barclays' Senir Eur Swaps Trader ed the Barclays Senir Euribr Submitter: "hi [Senir Euribr Submitter] is it pssible t have a high 6m ficxing [sic]? Where d yu think it will fix?" Barclays' Senir Euribr Submitter respnded: "Hi [Senir Eur Swaps Trader]. we have psted 3.73, hpe that helps.. can put in higher if yu like?" Barclays' Senir Eur Swaps Trader replied: "that's fine tx a lt fr yur help." 5) February 12, 2007: Barclays' Senir Eur Swaps Trader agreed with traders at Banks A and B t have their respective ne mnth Euribr submissins lwered. Barclays' Senir Eur Swaps Trader submitted that request t the Barclays Senir Em'ibr Submitter, stating: "hi [Senir Euribr Submitter]. Is it pssible t have a lw 1m fix tday?" Barclays' Senir Euribr Submitter replied: "will d." In ne instance f crdinatin ver a fur-mnth perid, the Barclays senir Eur swaps trader rchestrated an effrt t align trading strategies amng traders at multiple banks with the gal f influencing the fficial EBF three-mnth Euribr fixing n the Internatinal Mnetary Market ("IMM") date 19 f March 19,2007, in rder t prfit frm their futures trading psitins. This scheme began at least in December 2006 and cntinued until the March 2007 IMM date. It invlved multiple and successive requests ver this perid f time by the Barclays senir Eur swaps trader t Barclays' Euribr submitters and traders at ther banks t lwer the three-mnth Euribr submissin n dates leading up t and including the March 2007 IMM date. The fllwing are examples f the cmmunicatins invlved in this scheme: 19 IMM dates are standard quarterly settlement dates in March, June, September and December. Many derivatives cntracts are settled r reset n these dates, including varius Euribr futures cntracts. 17

18 1) December 27, 2006: Barclays' Senir Eur Swaps Trader: "Hi [Barclays Eur Swaps Trader]. A few things. Ask fr a lw 3m tday and ask [trader at Banle B] and [trader at Bank A] t put it lw as well." Tw days later, Barclays' Eur Swaps Trader ed the Euribr requests as instructed t the Barclays Euribr Submitters and the traders at the ther banks. 2) February 12, 2007: Barclays' Senir Eur Swaps Trader bragged t a trader at Banle D that he was ging t "push the cash t the basement" n the next IMM March date in rder t make mney n trades, claiming that he will have 80,000 lts in the Euribr futures cntract n it. He swre the trader at Banle D t secrecy, claiming that if they did nt keep the plan secret it wuld nt wrk. Barclays' Senir Eur Swaps Trader als claimed that his "treasury [r Euribr Submitter] has the pwer t mve 3m cash t the basement." 3) March 19, 2007: Barclays' Senir Eur Swaps Trader ed the Barclays Euribr submitter: "As discussed culd... put the 3m as lw as pssible... " The Barclays Euribr Submitter replied: "Will d my best." 4) March 20,2007: Barclays' Senir Eur Swaps Trader stated t trader at Banle A that they needed t have the three mnth Euribr fixing g up slwly t avid drawing any attentin. Barclays' Senir Eur Swaps Trader tld the trader at Banle A that he believed he was able t influence five ther panel member banles the day befre t lwer their Euribr submissins as they bth desired. Barclays' Euribr submitters knew it was imprper t cnsider swaps traders' derivatives trading psitins in determining the banle's Euribr submissins. A banle's financial derivatives trading psitins are nt legitimate r permissible factrs n which t base a banle's daily Euribr submissins. By basing its Euribr submissins upn Barclays' derivatives traders' requests, and thereby n Barclays' derivatives trading psitins, Barclays' Euribr submissins were nt cnsistent with the EBF's definitins and criteria fr Euribr submissins. Instead, Barclays cnveyed false, misleading r knwingly inaccurate reprts that its submitted rates fr Euribr were based n and slely reflected the csts f b011'0wing unsecured funds in the Eur mney market. Accrdingly, Barclays regularly attempted t manipulate and knwingly delivered false, misleading r knwingly inaccurate reprts cncerning Euribr, a cmmdity in interstate cmmerce. 18

19 3. During the Financial Crisis. Barclays Senir Management Directed that LIBOR Submissins Be Lwered During the financial crisis perid, Barclays directed its U.S. Dllar LIBOR submitters t lwer their daily U.S. Dllar LIBOR submissins in rder t prtect Barclays' reputatin against what it believed were negative and unfair media and market perceptins that Barclays had a liquidity prblem based in part n its high LIBOR submissins?o Beginning in August 2007, market cnditins began t deterirate significantly. At times during the financial crisis perid, there was severe illiquidity in the Lndn interbank mney market, resulting in n interbank lending in celiain tenrs. Barclays' U.S. Dllar LIBOR submitters cntinued t utilize the same factrs, as described abve, fr determining LIBOR submissins, but had substantially fewer transactins and ffers t cnsider which made determining Barclays' submissins mre difficult. Prir t the financial crisis perid, Barclays' U.S. Dllar LIBOR submitters cnsidered "reasnable size" fr a transactin by Barclays in the Lndn U.S. Dllar mney markets t be $250-$500 millin. During the financial crisis perid, a reasnable sized transactin was significantly lwer. Hwever, the LIBOR panel banle submitters were still required t adhere t the LIBOR definitin and criteria and submit rates based n their evaluatin f the csts f brrwing unsecured funds in the Lndn interbanle market. In late August 2007, Barclays' senir U.S. Dllar LIBOR submitter began ing liquidity repolis within Barc1ays, cmmenting abut the mney markets and ther banles. Initially, in these market reprts, the senir U.S. Dllar LIBOR submitter expressed his belief that in setting Barclays' submissin higher relative t thers, he was setting crrectly and that a number fbanles were submitting rates that were "unrealistically lw," particularly in a market envirnment where banks were reluctant t lend mney fr lnger than a ne-mnth perid. The senir U.S. Dllar LIBOR submitter ften acknwledged in these reprts that his wn U.S. Dllar LIBOR submissins were nt accurate, and were lwer than where he thught the cst f brrwing unsecured funds was fr Barclays. He recgnized, at times, that ifhe were t submit higher, accurate LIBORs, then the market r press wuld reprt that Barclays was experiencing difficulty in funding itself. On September 3, 2007, Blmberg featured Barclays in a news article entitled "Barclays Takes a Mney-Market Beating." The atiicle speculated that Barclays may have been having liquidity prblems, because n tw ccasins Barcla(,s had t brrw Sterling frm the emergency lending facility f the Banle f England,2 and because f Barclays' relatively high LIBOR submissins in Sterling, Eur and U.S. Dllar. The atiicle psed the questin, "S what the hell is happening at Barclays and its Barclays Capital securities unit that is prmpting its peers t charge it premium interest in the mney market?" Other newspapers, including the U.K. Financial Times and the Standard, ran similar articles abut LIBOR and Barclays. 20 At limited times this management directive als impacted submissins fr Sterling and Yen LIBOR. 21 Accrding t Bat'clays, Bat'clays had t brrw frm the Bank f England due t peratinal errrs caused by ther banks' late payments t Barclays. 19

20 On the day f the Blmberg article, Barclays' U.S. Dllar LIB OR submissins in at least three tenrs were the highest submissins f all panel banks, and were ver six t nine basis pints higher than the fficial BBA LIBOR fixing at thse tenrs. Barclays believed that its high LIBOR submissins caused its financial cnditin t be misperceived by the public and the media. The negative media speculatin caused significant cncern within Barclays and was discussed amng high levels f management within Barclays Banle. As a result, certain senir managers within Bat'clays Bank Treasury ("senir Barclays Treasury managers") instructed the U.S. Dllar LIBOR submitters and their supervisr t lwer Bat'clays' LIBOR submissins, s that they were clser in range t the submitted rates by ther banl(s but nt s high as t attract media attentin. Senir Bat'clays Treasury managers cined the phrase "head abve the parapet" t describe being an utlier n the U.S. Dllar LIBOR panel, which meant making high LIBOR submissins relative t the submitted rates f the ther banks and attracting media attentin. Senir Barclays Treasury managers directed Bat'clays' U.S. Dllar LIBOR submitters that their LIBOR submissins shuld nt be at a level where Barclays was "sticking its head abve the parapet," in rder t avid unwanted market and media attentin fr high LIBOR submissins that culd ptentially damage Barclays' reputatin. Senir Barclays Treasury managers prvided the submitters with the general guidance that Barclays' submitted rates shuld be within ten basis pints f the submissins by the ther U.S. Dllar panel banl(s t be in cmpliance with the directive. Barclays knew that accunting fr its reputatinal risk in its determinatin f LIBOR submissins was nt permissible under BBA's definitin and criteria. The submitters and their supervisr, hwever, understd that they were t fllw this directive regardless f market cnditins r whether their assessment f Barclays' cst f btaining unsecured funds dictated their submissins t be therwise. Barclays' U.S. Dllar LIB OR submitters knew that, by acting upn senir management's instructin t be belw "the parapet," they were making imprper U.S. Dllar LIBOR submissins that were management's rates and nt the rates that the submitters had detelmined were the crrect rates, i.e., thse that reflected Barclays' assessment f its cst f brrwing unsecured funds in the Lndn interbank mney market. The senir Barclays Treasury managers frequently discussed with the U.S. Dllar LIBOR submitters and their supervisr the specific rates t be submitted, in rder t ensure they were in cmpliance with the directive. In these discussins, the senir U.S. Dllar LIBOR submitter cnsistently made clear that they were nt setting Barclays' submissins at the rates that reflected Barclays' cst f btaining unsecured funds. These discussins were memrialized in multiple recrded telephne calls and s during the mre than I8-mnth financial crisis perid. Fr example, n Nvember 28,2007, Barclays' senir U.S. Dllar LIBOR submitter ed a large grup f Bar clays' emplyees, including the senir Bat'clays Treasury managers, stating "LIBORs are nt reflecting the true cst f mney. I am ging t set..., prbably at the 20

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