The 2013 and 2014 benchmark rigging orders

The library holds fifteen records on the CFTC and UK orders of 2013 and 2014 against banks and brokers over LIBOR, Euribor and FX benchmarks. The CFTC's six settled orders carry $2.446 billion across twelve named entities; the nine UK notices carry about 1.32 billion pounds. The two US bank orders of 2012 that the releases cite are not in the library.

Published 2026-10-04 · 12 min read

Between February 2013 and November 2014 the CFTC and the UK’s financial regulators announced settled orders over rigged benchmarks that, in the library, come to fifteen records. They concern two kinds of benchmark: the submission-based interest rates, LIBOR and Euribor, which banks set by reporting their own borrowing costs, and the foreign exchange fixes, which are calculated from trades. This post reads the CFTC releases and the UK final notices in the library for those matters, with the caveat that an AI agent did the reading and nobody with legal training has checked it, and that the CFTC orders themselves, which the releases link, were not read in full: the CFTC material below comes from the releases, and the UK material from the notices.

The matters on one line each

Each CFTC order has a record, and five of the six have UK notices in the library alongside them.

The February 2013 UK notice was issued by the Financial Services Authority, the FCA’s predecessor, and is hosted by the FCA; the library files it under the FCA.

What the CFTC said it found

The CFTC’s releases use the word finds because each is an order issued on settlement, in which the bank accepted terms; the releases say each order brings and settles the charges. Nothing below is a court finding after a trial.

RBS (February 2013). The order finds successful manipulation, attempted manipulation and false reporting of yen and Swiss franc LIBOR. By the release’s account, derivatives traders asked colleagues who made the bank’s submissions to move them whichever way suited their positions, and the submitters often did. The release says RBS put traders and submitters on the same desk and that the conduct continued after they were separated, through electronic chat. It also says RBS traders worked with a trader at a UBS subsidiary and with another panel bank’s trader, and that RBS executed wash trades to generate extra brokerage for two interdealer brokers who had helped UBS. The penalty is $325 million for RBS plc and RBS Securities Japan together. The release says RBS Securities Japan agreed to plead guilty to a wire fraud charge and RBS plc entered a deferred prosecution agreement, with $150 million accepted collectively, and that the UK authority imposed £87.5 million.

ICAP Europe (September 2013). ICAP is an interdealer broker, not a bank, and the order finds brokers on its yen desks knowingly sent false and misleading yen borrowing-rate information to market participants between October 2006 and January 2011, to aid a UBS yen trader’s attempts to move the fixing. The release says the trader called on the brokers more than 400 times, that the “suggested LIBORs” went to nearly all panel banks, that at least two banks’ submissions matched them up to 90% of the time, and that the broker who sent them was given compensation that grew to payments of $72,000. The penalty is $65 million. The release does not describe a US criminal action.

Rabobank (October 2013). The order finds false reporting and attempted manipulation of dollar, yen and sterling LIBOR and of Euribor, and successful manipulation of yen LIBOR, over nearly six years and involving more than two dozen employees in six offices on three continents. It also finds Rabobank at times aided other banks’ traders. The release says the conduct continued after the CFTC asked the bank in April 2010 to investigate its dollar LIBOR practices. The penalty is $475 million. The release lists related actions: a deferred prosecution agreement with the US Department of Justice and a $325 million payment, £105 million from the UK authority, a Japanese action over controls in Tokyo, remedial measures from the Dutch central bank and €70 million paid to avoid a Dutch prosecution.

RP Martin (May 2014). The order finds yen LIBOR manipulation, attempted manipulation and false reporting by brokers on the yen desk between September 2008 and August 2009, again to help a UBS yen trader. The release says they gave misleading recommendations to submitters, asked them to move, and at times posted cash bids that did not exist. It says they accepted more than $400,000 through wash trades set up to generate commissions. The penalty is $1.2 million for RP Martin Holdings and its subsidiary Martin Brokers.

Lloyds (July 2014). The order finds false reporting and attempted manipulation of sterling, dollar and yen LIBOR by employees of Lloyds TSB and HBOS, which Lloyds Banking Group acquired in January 2009, and that a few attempts succeeded. It says a Lloyds TSB yen submitter and a Rabobank submitter coordinated from mid-2006 to October 2008, and that in the last quarter of 2008 HBOS lowered its submissions to avoid looking like a desperate borrower. That last finding is not about trading positions. The penalty is $105 million for the two respondents, and the release records a Justice Department deferred prosecution agreement with an $86 million penalty and a £105 million UK penalty on Lloyds Bank and Bank of Scotland plc.

Five banks (November 2014). The five orders settle charges of attempted manipulation of, and aiding other banks’ attempts to manipulate, global foreign exchange benchmark rates, chiefly the WM/Reuters 4 p.m. closing spot rates. The release says traders coordinated with other banks in private chat rooms, shared customer order information and positions, and agreed trading strategies. Conduct began for some banks in 2009 and continued into 2012 for each. The orders also find the banks lacked controls over trader chat and over trading around the fixes. The penalties are $310 million each for Citibank and JPMorgan, $290 million each for RBS and UBS and $275 million for HSBC, which total $1.475 billion; the release says “over $1.4 billion”. These orders charge attempted manipulation and aiding and abetting, not completed manipulation, which is a real difference from the Rabobank and RBS orders.

What the UK notices charged

The UK notices are a different instrument. Each imposes a financial penalty under section 206 of the Financial Services and Markets Act 2000 for breaching the regulator’s Principles for Businesses, not for a market-manipulation offence by that name.

• RBS (6 February 2013): Principle 5, market conduct, between October 2006 and November 2010, and Principle 3, systems and controls, over the period January 2006 to March 2012. The notice counts at least 21 individuals involved and says RBS sought to manipulate yen and Swiss franc LIBOR submissions to benefit its derivatives books. The penalty is £87.5 million after a 30% settlement discount; the notice says it would otherwise have been £125 million.
• ICAP Europe (25 September 2013): Principles 5 and 3. The notice finds brokers colluded with two UBS traders to try to move other banks’ yen submissions, and counts at least 330 written requests from UBS; that is a different count from the CFTC’s “more than 400” calls. The penalty is £14 million, after a discount from £20 million.
• Rabobank (29 October 2013): Principles 2, 3 and 5. The notice counts at least 508 documented requests inside the bank to adjust LIBOR submissions to suit trading positions, 384 for yen, 112 for dollars and 12 for sterling, with at least 26 individuals involved. It says there was no documented evidence of attempts after January 2011. The penalty is £105 million, after a discount from £150 million. The notice covers LIBOR only, not the Euribor conduct in the CFTC order.
• Martin Brokers (15 May 2014): Principles 5 and 3, between 2007 and 2010. The notice says the regulator would have fined £3.6 million, cut that by 75% because the firm could not pay it and agreed instalments, and then applied a 30% settlement discount to reach £630,000.
• The five FX notices (11 November 2014): these charge a breach of Principle 3 only, for failing to control G10 spot FX voice trading, between 1 January 2008 and 15 October 2013, at the London desks of Citibank, HSBC, JPMorgan and RBS and the Zurich desk of UBS. The notices say those control failures allowed behaviours including attempts to manipulate the WM/Reuters and ECB fixes in collusion with other firms and attempts to trigger clients’ stop-loss orders. The penalties, each after a 30% discount, are £225.575 million for Citibank, £216.363 million for HSBC, £222.166 million for JPMorgan, £217 million for RBS and £233.814 million for UBS, £1,114.918 million in all, which matches the total the CFTC release gives.

The money, with the caveats

The six CFTC orders carry $2,446.2 million in penalties across twelve named entities (RBS plc appears in two orders). That is the sum of the figures the releases state; where an order names two companies, as for RBS and RBS Securities Japan or Lloyds Banking Group and Lloyds Bank, the release gives one penalty for both and the library does not split it. The five-bank order is $1.475 billion of that sum, 60%, and it is the second-largest penalty in the whole library after the Stanford judgment. The November 2014 CFTC release states a cumulative figure of over $3.34 billion for benchmark penalties since June 2012; the six orders here plus the Barclays and UBS orders it lists, $200 million and $700 million, reach $3,346.2 million, which fits.

The nine UK notices carry £1,322.048 million after settlement discounts. Do not add the two charts. The sterling and dollar figures are separate sets, in their own currencies, and the library does not convert them. The same conduct is penalised twice in two currencies by two regulators in several of these matters, in addition to the Justice Department and other agencies’ amounts the releases mention that the library does not record. The penalty counts are also not harm: none of these documents measures a loss to anyone who traded against a benchmark.

What the matters establish, and what they leave open

They establish a pattern, in the regulators’ words. In the LIBOR orders a person whose positions settled on the rate influenced what the submitting bank reported, directly or through a broker, and the orders and notices attribute that to specific desks over years, with documentary counts such as 508 requests at Rabobank and 96 written requests to RBS submitters over two years. The broker orders show the technique reaching people who submitted nothing. The FX orders show the same incentive in a benchmark set from trades, where the conduct the orders describe is coordination in chat before the fix. That is the core of the benchmark submission rigging tag, and the FX fixing tag covers the second kind.

They also show the tags need care. The library tags the RP Martin and Martin Brokers records with wash trading and spoofing and the RBS records with wash trading and cash vs derivatives schemes. In the releases wash trades and non-existent bids are mechanisms around the main conduct, the first as a way of paying brokers; the Lloyds order also describes bids raised in the sterling cash market to move a fixing. The matters were not charged as wash trading or spoofing. The wash trading and price manipulation pages should be read with that in mind, as should cash vs derivatives schemes. For the design reasons that made submission-based rates vulnerable, see the post on LIBOR and benchmark design.

They do not establish how often a fixing moved, by how much, or who lost. They do not establish that every panel bank was involved. The CFTC’s orders in the FX matters are for attempts. The UK FX notices are for control failures. The sums are settlements agreed at an early stage with a discount, not penalties set after contest, and they say little about the individuals, whose cases are separate records: the library holds eleven UK final notices against individuals dated 2015 to 2022, and the later bank orders of 2015 to 2018, none of which this post covers (see the technique page).

They are an incomplete set. The CFTC releases cite a June 2012 Barclays order ($200 million) and a December 2012 UBS order ($700 million), and name a UK notice against Lloyds Bank and Bank of Scotland plc, and the Justice Department and other regulators’ actions. The library has no record of any of those, so no total here is the whole of the benchmark enforcement of 2012 to 2014. The library holds no benchmark record dated 2012, so a chart of its benchmark cases by year would start in 2013.

Sources and limits

The primary documents are the CFTC releases 6510-13, 6708-13, 6752-13, 6930-14, 6966-14 and 7056-14, and the UK final notices linked from each case page above. The CFTC orders themselves, and the other notices’ full texts beyond their opening and summary sections, were read only in part. Two of the six CFTC case records, Lloyds and RP Martin, carry the status “judgment” in the library; the releases describe settled administrative orders, and this post follows the releases. Errors can be reported by the link on any case page or to [email protected].

Techniques referenced

• Benchmark submission rigging — Benchmark submission rigging is skewing the figures a panel member reports into a reference rate calculation, so that the published benchmark moves in favour of positions that settle against it.
• FX fixing — FX fixing manipulation is trading during the short window used to calculate a daily currency benchmark, using advance knowledge of client orders that must be executed at that fix.
• Price manipulation — Price manipulation is trading intended to create an artificial price — one that does not reflect genuine supply and demand — and it is the general charge a regulator brings when the conduct does not fit a more specific named technique.
• Cash versus derivatives schemes — A cash versus derivatives scheme establishes a large derivative position and then trades the smaller underlying market at a deliberate loss, in order to move the reference price the derivative settles against.
• Wash trading — Wash trading is buying and selling the same asset with no change in beneficial ownership and no market risk, so that a trade prints publicly and creates a false impression of activity or price.

Cases referenced

Reviewed October 4, 2026. Spotted an error? Tell us.