Brown Rudnick

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Chloe Pawson Pounds
Partner
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David Knight
Partner
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Helen Vlachos
Law Librarian, Senior Research Services Manager
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Ian Weinstein
Associate
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Karen Gordon
Law Librarian
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Contributions by Brown Rudnick

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Benchmark enforcement action—essentials
Benchmark enforcement action—essentials
Practice Notes

This Practice Note considers enforcement actions by regulators and competition authorities, in addition to criminal prosecutions, surrounding the manipulation of benchmarks, including LIBOR, EURIBOR and Forex (FX). It discusses cross-border investigations into benchmark manipulation, and international coordination in relation to enforcement action; it also considers consequential litigation arising from civil and criminal actions. It considers LIBOR reforms that followed and the investigatory and enforcement powers and penalties under Regulation (EU) 2016/1011 (the EU Benchmarks Regulation) and Retained Regulation (EU) 2016/1011 (the UK Benchmarks Regulation). The Practice Note includes tables setting out the regulatory actions taken against both firms and individuals for benchmark manipulation; these include: the names of firms/individuals; links to the FCA/FSA Final Notice and related press release; the breaches/failings; the FCA/FSA financial penalty/enforcement action; and related UK/international civil/criminal penalties.

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