Benchmark enforcement action—essentials
Produced in partnership with Brown Rudnick

The following Financial Services practice note produced in partnership with Brown Rudnick provides comprehensive and up to date legal information covering:

  • Benchmark enforcement action—essentials
  • What is LIBOR?
  • The Wheatley review of LIBOR and LIBOR reforms
  • Adequacy and scope of sanctions
  • Enforcement cases arising out of LIBOR
  • Criminal action
  • International coordination in enforcement
  • EU enforcement
  • EU Benchmarks Regulation
  • Transition away from LIBOR
  • More...

Benchmark enforcement action—essentials

BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see: Brexit and financial services: materials on the post-Brexit UK/EU regulatory regime.

Lexis®PSL Financial Services Enforcement Database: This incorporates detailed information on all substantive FCA and PRA Final Notices and, where available, Decision Notices from 2014 to 2020. The Database, available here, may be searched and filtered by rule breach, keyword, sector, date, seriousness, aggravating and mitigating factors, financial penalty, and other actions such as appeals.

Over the past decade, there have been major concerns surrounding the administration and manipulation of financial market benchmarks, which have led to investigations by regulators around the world and consequent enforcement action. Partly as a consequence of this enforcement action, changes have been made to the way in which these benchmarks are being run and administered. The benchmarks which have been the focus of enforcement action include foreign exchange, gold fixing and gilts, among others. However, much of the enforcement action and media attention has centred around the manipulation of LIBOR.

This Practice Note

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