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U.S.D.C., CT

London Interbank Offered Rate (LIBOR) is an average interest rate, with calculations based upon submissions from leading banks around the world, reflecting the rates those banks believe they would be charged, if borrowing from other banks. The LIBOR is published by the British Bankers’ Association, a trade association in London, which also selects the panel of bankers (the Contributor Panel) upon whose submissions the calculations are based. The LIBOR serves as the primary benchmark for short-term interest rates globally, and is also a reference point for many interest rate contracts, mortgages, credit cards, student loans, and consumer lending products.

From approximately, ________ through the present, the defendant, Lloyds Banking Group (through its subsidiaries), has been a member of the Contributor Panel for a number of currencies, including United States Dollar LIBOR, Pound Sterling LIBOR, and Yen LIBOR. The United States Department of Justice charged that between around ________, and as late as July ________, the defendant’s submitters for the Dollar, Yen, and Pound Sterling LIBOR, submitted LIBOR contributions intended to benefit their own trading positions, or the trading positions of others, rather than rates that complied with the definition of LIBOR. If true, the manipulation of the submissions affected the fixed rates on occasion. The DOJ argued that, because investors and consumers rely on LIBOR’s integrity, rate-rigging fundamentally undermines confidence in financial markets.

On July 28, ________, a criminal information was filed in the U.S. District Court for the District of Connecticut, charging the defendant with wire fraud for its role in manipulating LIBOR. The charges were entered as part of a deferred prosecution agreement between the parties.Defendant has agreed to pay $________ in civil penalties for manipulation of submissions for LIBOR, as well as agreeing to admit and accept responsibility for its misconduct as described in an extensive statement of facts. The defendant agreed to cooperate with the Department of Justice in in its ongoing investigation of the manipulation of benchmark interest rates by other financial institutions and individuals.

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