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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

The six CFTC orders of 2013 and 2014 in the library, by date, with the penalty in millions of US dollarsA timeline of the six CFTC settled orders in the library in date order, each with the penalty its release states in millions of US dollars. 6 February 2013, The Royal Bank of Scotland plc and RBS Securities Japan, 325 million, yen and Swiss franc LIBOR. 25 September 2013, ICAP Europe, 65 million, yen LIBOR. 29 October 2013, Rabobank, 475 million, LIBOR and Euribor. 15 May 2014, RP Martin Holdings and Martin Brokers, 1.2 million, yen LIBOR. 28 July 2014, Lloyds Banking Group and Lloyds Bank, 105 million, LIBOR. 12 November 2014, five banks, 1,475 million in total, foreign exchange benchmarks. The CFTC releases also cite orders against Barclays in June 2012 and UBS in December 2012, which are not in the library. Feb 2013RBS, $325m Sep 2013ICAP, $65m Oct 2013Rabobank, $475m May 2014RP Martin, $1.2m Jul 2014Lloyds, $105m Nov 20145 banks, $1,475m

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

MatterCFTC recordUK recordWhat the benchmark was
RBS, February 2013CFTCFSA noticeYen and Swiss franc LIBOR
ICAP Europe, September 2013CFTCFCAYen LIBOR, through broking
Rabobank, October 2013CFTCFCADollar, yen and sterling LIBOR; Euribor in the CFTC order
RP Martin, May 2014CFTCFCAYen LIBOR, through broking
Lloyds, July 2014CFTCnone in the librarySterling, dollar and yen LIBOR
Five banks, November 2014CFTCCitibank, HSBC, JPMorgan, RBS, UBSForeign exchange benchmark rates

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.

The route the ICAP and RP Martin orders describe from a bank trader to the yen LIBOR fixingA flow diagram of the broker route as the CFTC releases for ICAP Europe and RP Martin describe it. A senior yen derivatives trader at a UBS subsidiary asks interdealer brokers for help. The brokers send panel banks suggested or run-through rates that reflect the trader preferred level and not an honest estimate, and ask submitters directly to move. Panel banks make their daily submissions, partly informed by the broker view, and the published yen LIBOR is calculated from those submissions. The orders state that the brokers did this to keep a valuable client and, in the ICAP and RP Martin orders, were paid in other ways. This is a schematic of the described route, not a record of one day. requestssuggested ratessubmissions Derivatives traderposition settles on theyen rate Interdealer brokerICAP or Martin Brokersdesk Panel bankssubmitters get thebroker view Published yen LIBORaverage of trimmedsubmissions

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.

The money, with the caveats

CFTC civil penalties in the 2013 and 2014 orders, by respondent, in millions of US dollarsA horizontal bar chart of the CFTC penalties in the six orders, in millions of US dollars, one bar per order or per bank. Rabobank 475. RBS plc and RBS Securities Japan 325, a single figure for the two. Citibank 310 and JPMorgan Chase Bank 310, each in the foreign exchange orders. The Royal Bank of Scotland plc 290 and UBS AG 290 in the foreign exchange orders. HSBC Bank plc 275. Lloyds Banking Group and Lloyds Bank 105, one figure for the two. ICAP Europe 65. RP Martin Holdings and Martin Brokers 1.2, one figure for the two. The bars add to 2,446.2 million. RBS appears twice, once for the LIBOR order and once for the foreign exchange order, and the two are different orders.Rabobank $475m LIBOR, EuriborRBS plc and RBS Japan $325m LIBOR, one figureCitibank N.A. $310m FXJPMorgan Chase Bank $310m FXRBS plc $290m FXUBS AG $290m FXHSBC Bank plc $275m FXLloyds Group and Bank $105m LIBOR, one figureICAP Europe $65m LIBORRP Martin and Martin Brokers $1.2m LIBOR, one figure

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.

UK regulator penalties in the 2013 and 2014 final notices in the library, in millions of pounds sterlingA horizontal bar chart of the nine UK final notices in the library, in millions of pounds sterling, after each settlement discount. UBS AG 233.814 million, Citibank N.A. 225.575, JPMorgan Chase Bank N.A. 222.166, The Royal Bank of Scotland plc 217 and HSBC Bank plc 216.363, all from November 2014 foreign exchange notices and adding to 1,114.918 million. Rabobank 105 million from October 2013. The Royal Bank of Scotland plc 87.5 million from February 2013. ICAP Europe 14 million from September 2013. Martin Brokers 0.63 million from May 2014. The bars add to 1,322.048 million pounds. A Lloyds penalty of 105 million pounds cited in a CFTC release is not in the library.UBS AG £233.814m FXCitibank N.A. £225.575m FXJPMorgan Chase Bank £222.166m FXRBS plc £217m FXHSBC Bank plc £216.363m FXRabobank £105m LIBORRBS plc £87.5m LIBORICAP Europe £14m LIBORMartin Brokers (UK) £0.63m LIBOR

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

Cases referenced

Action Agency Filed Technique Penalty Status
CFTC v. The Royal Bank of Scotland plc and RBS Securities Japan Limited (benchmark submission rigging, 2013) CFTC 2013-02-06 Benchmark Submission Rigging , Price Manipulation +1 $325m settled
FCA v. The Royal Bank of Scotland plc (benchmark submission rigging, 2013) FCA 2013-02-06 Benchmark Submission Rigging , Cash Vs Derivatives Schemes +2 — settled
CFTC v. ICAP Europe Limited (benchmark submission rigging, 2013) CFTC 2013-09-25 Benchmark Submission Rigging , Price Manipulation $65m settled
FCA v. ICAP Europe Ltd (benchmark submission rigging, 2013) FCA 2013-09-25 Benchmark Submission Rigging , Price Manipulation — settled
CFTC v. Rabobank (benchmark submission rigging, 2013) CFTC 2013-10-29 Benchmark Submission Rigging , Price Manipulation $475m settled
FCA v. Coöperatieve Centrale Raiffeisen–Boerenleenbank B.A. (‘Rabobank’) (benchmark submission rigging, 2013) FCA 2013-10-29 Benchmark Submission Rigging , Cash Vs Derivatives Schemes +1 — settled
CFTC v. RP Martin Holdings Limited and Its Subsidiary (benchmark submission rigging, 2014) CFTC 2014-05-15 Benchmark Submission Rigging , Price Manipulation +1 $1.2m settled
FCA v. Martin Brokers (UK) Ltd (Martins) (benchmark submission rigging, 2014) FCA 2014-05-15 Benchmark Submission Rigging , Price Manipulation +2 — settled
CFTC v. Lloyds Banking Group and Lloyds Bank (benchmark submission rigging, 2014) CFTC 2014-07-28 Benchmark Submission Rigging , Cash Vs Derivatives Schemes +1 $105m settled
CFTC v. Citibank, HSBC, JPMorgan, RBS and UBS (FX benchmark manipulation, 2014) CFTC 2014-11-12 Benchmark Submission Rigging , FX Fixing +1 $1.5bn settled
FCA v. Citibank N.A. (FX benchmark manipulation, 2014) FCA 2014-11-11 FX Fixing — settled
FCA v. HSBC Bank plc (FX benchmark manipulation, 2014) FCA 2014-11-11 FX Fixing — settled
FCA v. JPMorgan Chase Bank N.A. (FX benchmark manipulation, 2014) FCA 2014-11-11 FX Fixing — settled
FCA v. The Royal Bank of Scotland plc (FX benchmark manipulation, 2014) FCA 2014-11-11 FX Fixing — settled
FCA v. UBS AG (FX benchmark manipulation, 2014) FCA 2014-11-11 FX Fixing — settled

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