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LIBOR

LIBOR methods, enforcement records and transition dates, with submissions, published rates and legal outcomes kept distinct.

Built from a research dossier; admission and independent checking of this account are not supplied in this view. Source attribution does not establish independent corroboration. Read the full dossier · Inspect

LIBOR connected financial contracts to published interest-rate benchmarks, but its settings did not share one unchanged method throughout their history. To understand a setting, a reader needs its currency, tenor, date and calculation rules. The retained record distinguishes banks’ submissions from the published panel average, the later transaction-prioritizing waterfall from earlier assessments, and temporary synthetic settings from the markets the bank panels had sought to measure.

Enforcement and legal outcomes also require their own boundaries. The Barclays regulatory and Justice Department records describe particular findings, admissions and penalties; later records concern different institutions and proceedings. In July 2025 the UK Supreme Court quashed Hayes’ and Palombo’s convictions after finding errors in jury directions. That result must be stated alongside, without being enlarged into a reversal of every institutional resolution. This dossier compares those records, separates the June 2023 panel ending from final synthetic publication in September 2024, and leaves daily-rate effects, contract-specific losses and worldwide penalty totals unresolved.

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Contents and source readers

14 research source candidates. Only recorded, eligible public Source destinations appear above.

Scope

LIBOR was a family of interest-rate settings, not one continuously comparable number. A useful description identifies the currency, tenor, observation date, contributor population and method. This dossier follows three related but distinct records: benchmark construction and reform; selected institutional enforcement actions and individual appeals; and the wind-down of panel and synthetic publication.

The methodological comparison starts with the 2012 Wheatley Review and the historical definitions discussed in the retained Barclays orders and 2025 Supreme Court judgment. It then moves to ICE's April 2019 transition announcement and its expressly bounded USD methodology for 4 January 2022 through 30 June 2023. The transition account distinguishes the last bank panel's cessation from the final synthetic publication. The enforcement comparison uses Barclays' June 2012 US/UK components, dated UBS and RBS announcements and the August 2016 multistate Barclays settlement. It ends with the two appeals decided in R v Hayes; R v Palombo [2025] UKSC 29, without claiming a later docket search.

EURIBOR appears because some proceedings concern both benchmarks and Palombo's appeal concerns EURIBOR. It is not another name for euro LIBOR. The historical definitions, panel populations and trimming rules differ. Neither this comparison nor LIBOR's cessation establishes that EURIBOR ceased.

Key distinctions

  • Submission versus setting: A bank contributes an input; the administrator calculates a benchmark from a panel. A changed input does not mechanically imply an equal change in the published setting.
  • Setting versus transaction: A published benchmark can enter a contract's interest formula. It is not itself a record of every bank loan, trade or borrower payment.
  • Could borrow versus did borrow: The historical submission question required an assessment. An actual borrowing transaction may inform that assessment without exhausting it.
  • Methodological period: Historical judgment-based submissions, transaction-prioritizing waterfall submissions and synthetic settings cannot be flattened into a timeless estimate-only description.
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  • Weighting at two stages: A volume-weighted input within a contributing bank is different from the equal weighting of retained bank submissions in the panel's trimmed mean.
  • Eligibility versus representativeness: A methodology's eligible trades are a specified input set. They are not a census or random sample of all borrowing, nor proof that every contract using the resulting rate faces the same risk.
  • LIBOR versus EURIBOR: Similar names and overlapping enforcement records do not make their definitions, currencies or legal obligations interchangeable.
  • Attempt, false report and effect: The particular violation or finding must be named. Attempted manipulation, false reporting, an altered submission and measured benchmark impact are different propositions.
  • Institution versus individual: A corporate settlement, a subsidiary's agreement to plead and an individual's conviction or appeal concern different persons and procedures.
  • Currency and remedy: US-dollar penalties, a sterling financial penalty, restitution and disgorgement cannot be added without an explicit scope, conversion and duplicate-counting rule.
  • Date roles: Misconduct periods, announcement dates, judgment dates, methodology applicability and the 2026 retrieval date are separate.
  • Panel end versus final publication: 30 June 2023 and 30 September 2024 describe different LIBOR milestones.
  • Alternative versus universal fallback: SOFR is a USD alternative. A currency map is not a determination of every contract's replacement rate, spread or legal effectiveness.
  • Legal error versus universal vindication: The 2025 judgment quashes the two appellants' convictions; it is not an order vacating all institutional resolutions or a finding that every historical submission was sound.

Analysis

LIBOR connects measurement design to incentives and institutional judgment. A reader can agree that misconduct occurred in a particular proceeding while still asking what effect a particular submission had on a particular setting. The calculation matters to that question: trimming may exclude an input, but it does not provide a general immunity from coordinated or strategically placed inputs. The necessary evidence for a daily effect is narrower and more demanding than a broad headline about a scandal.

The later record complicates an equally simple rehabilitation story. Reform changed the submission methodology, but the continued dependence on a fragile underlying market helped motivate transition. A synthetic rate could continue to serve a limited legacy function while being declared permanently unrepresentative of the market previously measured. The same familiar name therefore does not promise the same object through time. These distinctions let the reader inspect what each source actually establishes without turning a source's authority in one domain into authority over every related question.

Temporal bounds

The selected enforcement record begins with conduct and controls periods described as starting in 2005, with narrower dates for particular findings. Barclays' CFTC order, FSA notice and DOJ announcement are dated 27 June 2012. The Wheatley final review is from September 2012; the retained manifest records publication on 28 September. The UBS and RBS announcements are dated 19 December 2012 and 6 February 2013, while the multistate Barclays settlement announcement is dated 8 August 2016. These announcement dates are not the dates of every underlying act or of later completion of an agreement.

ICE announced completion of the waterfall transition on 1 April 2019. The retained USD panel methodology expressly applies from 4 January 2022 through 30 June 2023. The last bank panel ended on 30 June 2023, as reported by the FCA on 3 July; remaining synthetic settings continued until their final publication on 30 September 2024, reported in the joint release on 1 October. The Supreme Court delivered its Hayes/Palombo judgment on 23 July 2025. All fourteen research representations were downloaded on 6 November 2026; that retrieval date neither backdates a living webpage nor supplies later legal or contractual outcomes.

Questions in the research record

Questions the research dossier keeps separate, each with the positions and limits it records for the institutions involved. This is research analysis, not admitted findings.

An assessment is not necessarily an invented number

The historical LIBOR question asked for the rate at which a contributing bank could borrow under specified conditions. In its discussion of the periods relevant to the appeals, the Supreme Court describes the assessment as dependent on available quotations, transaction sizes, liquidity and other information; it could involve a range of defensible figures (Supreme Court judgment in Hayes and Palombo, paragraphs 19–22). That does not mean any number was equally valid. It means the truth of a purported assessment and the submitter's state of mind cannot be replaced by a mechanical assertion that one uniquely observable number always existed.

The Wheatley Review's recommended transaction hierarchy addresses this evidential problem. It prioritizes the contributing bank's transactions, then observations and quotations, and permits expert judgment where necessary (Wheatley reform review, printed p. 28 / PDF p. 32). It proposes corroboration, controls and records. A recommendation to improve transaction support is evidence of the proposed reform, not proof that every earlier submission lacked evidence or that every later submission complied.

The waterfall has two calculation stages

The retained USD methodology first determines each contributor's submission. Level 1 uses eligible transactions; Level 2 uses transaction-derived data where Level 1 is unavailable; Level 3 uses framed expert judgment when neither prior level is available. The document's Level 1 volume-weighted calculation operates inside a bank's contribution. It does not make the final benchmark a volume-weighted average of all underlying loans (USD panel methodology, 2022–2023, pp. 2–4).

At the panel stage, submissions are ranked and trimmed; the remaining submissions receive equal weights. The retained document's 15-contributor table removes four highest and four lowest rates and averages seven. This concrete table is preferable to pretending that “quartile” always produces an exact 25 percent count for every possible panel size. It also differs from the historical 16-bank/eight-retained example in the judgment (Supreme Court judgment in Hayes and Palombo, paragraph 20). Neither number is a universal panel count.

Eligibility narrows the observed data: the USD document specifies funding instruments, counterparties, minimum sizes, a minimum number of trades, approved funding centres and tenor buckets. For example, pp. 4–5 require at least two trades with different counterparties for Levels 1/2 and a USD 10 million trade threshold; the one-month bucket spans 25–35 calendar days. These are methodology-specific selection rules, not a claim that the dataset samples all wholesale borrowing randomly. An empirical assessment of which banks used which levels on a given day would need the actual submissions and input records, absent from this dossier.

Reform, representativeness and continuity answer different questions

ICE's 1 April 2019 announcement says all panel banks completed the waterfall transition, while expressly declining to guarantee publication beyond end-2021 (ICE waterfall transition announcement). The later USD methodology documents five continuing panel tenors for a specified period. The FCA's 3 July 2023 account then distinguishes cessation of overnight/12-month USD settings from temporary synthetic 1-, 3- and 6-month settings (End of the USD bank panel).

Those synthetic settings used the relevant CME Term SOFR reference rate plus the respective ISDA fixed spread adjustment, according to the dated FCA account. The same account says they were permanently unrepresentative of the underlying markets they had previously sought to measure. Continued publication therefore does not prove continued panel representativeness. Conversely, that designation does not mean no legacy contract could lawfully use them: the account describes a particular temporary permission and new-use prohibition. This dossier does not inspect every underlying notice or apply it to a particular contract.

Regulatory findings and individual criminal appeals cannot be collapsed

The CFTC order contains findings of attempted manipulation and false reporting, entered on an accepted settlement offer. Its consent language is qualified by related admissions; it is not simply a criminal conviction or an unqualified denial of all facts (CFTC Barclays settlement order, p. 1). The FSA Final Notice imposes a financial penalty for Principles 2, 3 and 5 breaches (FSA Final Notice to Barclays, paragraphs 1–21). The DOJ announcement says Barclays admitted the incorporated misconduct and entered a conditional non-prosecution agreement, applying to Barclays rather than its employees (DOJ Barclays agreement announcement).

The Supreme Court's 2025 judgment addresses whether the jury directions in the Hayes and Palombo trials improperly displaced factual questions about genuine assessments and fraudulent representations. Its answer to both limbs of the certified question is no, and it quashes the two convictions (Supreme Court judgment in Hayes and Palombo, paragraphs 5–7 and 234–235). Palombo's EURIBOR discussion also distinguishes contractual obligations from the criminal-law impression conveyed by the directions (paragraphs 231–233). An accurate account needs both the institutional record and the later appellate correction. Saying that a regulator made a finding does not dispose of the appeal; saying the convictions were quashed does not enlarge the judgment into a universal order concerning other resolutions.

Motive, direction of input and effect on a setting

The CFTC/FSA records distinguish trader requests aimed at benefiting positions from reputation-related lowering during the financial crisis. A trader could favor a higher or lower input depending on the book; lowballing should not become the sole mechanism for every recorded act. The FSA also gives different date ranges for the trader-request and reputation findings and for deficient controls. These are bounded findings, not one continuous rate-distortion estimate.

A particularly useful qualification appears in CFTC p. 4 footnote 2: the Commission did not find evidence of intent to affect the official published LIBOR through the reputation-related directive, although Barclays' submissions were sometimes included in the calculation. DOJ separately reports some occasions when submissions affected fixed rates (DOJ Barclays agreement announcement). These statements concern purpose, inclusion and effect respectively. They should not be compressed into either “every lowered submission changed the fix” or “there was never an effect.” This dossier has no daily counterfactual reconstruction or loss estimate.

Penalty components retain their units and legal roles

Dated recordEntity / authorityRecorded amount and roleLimit
27 June 2012Barclays; DOJ announcementUSD 160 million penalty under the announced non-prosecution agreementNot a criminal conviction of every employee
27 June 2012Barclays respondents; CFTC orderUSD 200 million civil monetary penaltyThe order and its announcing release report the same component
27 June 2012Barclays Bank Plc; FSA Final NoticeGBP 59.5 million financial penalty after a 30% early-settlement discountGBP 85 million is the stated undiscounted counterfactual, not an additional payment
19 December 2012UBS Japan / UBS AG; DOJ announcementUSD 100 million agreed subsidiary fine plus USD 400 million parent NPA penaltySigned/announced arrangements at that date; underlying attachments and later dispositions not read here
6 February 2013RBS Japan / RBS parent; DOJ announcementUSD 50 million agreed subsidiary fine plus USD 100 million parent DPA penaltyPreserve subsidiary plea agreement versus parent deferred prosecution
8 August 2016Barclays; Connecticut multistate announcementReports USD 100 million total, USD 93.35 million restitution and USD 6.35 million costs/expensesReported components total USD 99.70 million: USD 0.30 million below the stated total. Discrepancy unresolved; not part of the June 2012 event

The 2016 Connecticut announcement has an internal numerical discrepancy: its USD 93.35 million restitution plus USD 6.35 million costs/expenses equals USD 99.70 million, not the stated USD 100 million total. The gap is USD 0.30 million. These remain attributed reported amounts, not a reconciled allocation. No USD 6.65 million correction, omitted component or rounding explanation is inferred without further documentary evidence (Connecticut multistate Barclays settlement announcement).

The three June 2012 Barclays components are displayed in their original currencies. No USD 435 million total is used; no USD-equivalent total is computed without a dated exchange-rate basis. The review specification's approximately USD 453 million summary refers to a Joint Economic Committee account not included among these fourteen retained bodies, so that conversion is not presented as independently checked here. The worldwide USD 9 billion claim is omitted because this selection supplies no complete, non-duplicative global inventory. An announcement's converted UBS/RBS aggregate likewise must not be summed with its components as a new finding.

Questions and evidence limits

Provisional claim analyses from the research dossier: a proposed wording, its candidate sources, and what those sources can and cannot establish. They are research interpretation, not admitted claims, findings or decisions. Where the dossier writes “Refusal branch” or “Reopening condition”, it proposes when a broader formulation should be withheld or reconsidered; no refusal or standing decision has been made.

Methodology changed through time

Provisional reader wording

LIBOR's submission methods changed: the 2012 review recommended stronger transaction support; ICE announced completion of the waterfall transition in April 2019; its retained USD methodology defines a three-level input process for five panel tenors from January 2022 through June 2023.

Candidate research source cards, not new bindings

What this analysis can establish

The sources distinguish recommendation, administrator announcement and a specific methodology's applicability. The 2022–2023 document retains framed expert judgment as a third level while prioritizing eligible transactions and transaction-derived data.

What it cannot establish / reason to qualify a stronger claim

This does not establish which waterfall level every bank used on every day, prove perfect compliance or extend USD eligibility rules to another currency or historical period.

Standing and next check

Provisional research analysis only. A stronger empirical claim needs date-specific submission/input records and the applicable method, without substituting a press release for actual execution evidence.

A published setting is a selected and aggregated measure

Provisional reader wording

In the retained USD methodology, eligible transactions inform bank submissions through a waterfall; the administrator then trims and equally averages retained bank submissions. The published setting is not a volume-weighted census of all bank borrowing.

Candidate research source cards, not new bindings

What this analysis can establish

The document specifies the two stages, eligibility rules, tenor buckets and 15-contributor/seven-retained table. The judgment's historical 16-contributor/eight-retained example demonstrates why panel counts need a date and source.

What it cannot establish / reason to qualify a stronger claim

The methodology does not alone quantify sampling error, daily representativeness, manipulation impact or losses on an individual contract. Trimming is not proof that an input change was harmless.

Standing and next check

Provisional research analysis only. A daily-effect inquiry requires the actual panel submissions, correct trimming and a defended counterfactual, followed by the relevant contract terms if payment consequences are claimed.

Barclays' 2012 institutional record has three distinct components

Provisional reader wording

The June 2012 Barclays record contains a USD 200 million CFTC civil penalty, a GBP 59.5 million FSA financial penalty and a USD 160 million DOJ agreement penalty, with distinct findings, admissions and procedural terms.

Candidate research source cards, not new bindings

What this analysis can establish

The retained order, notice and announcements identify amounts, entities and procedural forms. Trader-request conduct and reputation-related lowering are separately described and dated.

What it cannot establish / reason to qualify a stronger claim

These amounts are not an unconverted single-currency total, a measure of all investor losses or a conviction of every person involved. The CFTC release is not independent corroboration of the order it summarizes.

Standing and next check

Provisional research analysis only. Contract-specific liability or a worldwide aggregate would require additional records and an explicit legal/entity/date/remedy scope; neither is supplied by this local inventory.

Two cessation milestones describe different objects

Provisional reader wording

The last LIBOR bank panel ended on 30 June 2023. Temporary synthetic settings continued thereafter; the remaining settings were published for the final time on 30 September 2024, according to the dated FCA and joint institutional accounts.

Candidate research source cards, not new bindings

What this analysis can establish

The accounts distinguish overnight/12-month USD cessation from continued synthetic 1-, 3- and 6-month USD settings, and identify the final publication milestone. The retained transition page supplies a currency-specific alternative-rate map.

What it cannot establish / reason to qualify a stronger claim

It does not determine every contract's fallback, eliminate historical payment disputes or make SOFR the universal replacement for all currencies. The living transition page is a 2026 snapshot, not a contemporaneous 2019 page.

Standing and next check

Provisional research analysis only. For a particular contract, obtain its governing language, amendments and applicable measures rather than inferring substitution from the benchmark's public timeline.

The 2025 judgment must be read at its actual scope

Provisional reader wording

On 23 July 2025 the UK Supreme Court allowed Hayes' and Palombo's appeals and quashed their convictions, identifying errors in jury directions about the disputed submissions and fraudulent representations. That disposition concerns those two appeals.

Candidate research source cards, not new bindings

What this analysis can establish

The retained judgment records the certified question, reasoning and operative conclusion. Hayes' case concerns LIBOR; Palombo's concerns EURIBOR. Paragraphs 5–7 distinguish a legal construction from the factual question whether the submitted opinion was genuinely held, and paragraphs 231–235 address Palombo and the result.

What it cannot establish / reason to qualify a stronger claim

The result is not a finding that every submission was proper, an automatic reversal of every other case or an order rescinding the separately identified institutional resolutions. The annex reproduces trial directions being examined; it must not be quoted as the Supreme Court endorsing those directions.

Standing and next check

Provisional research analysis only. Any claimed consequence for a different person or resolution needs that proceeding's actual later record. This draft makes no fresh current-docket assertion.

Why not?

BEST "WHY NOT?" SPECIMEN

Why not say that every inaccurate bank submission changed the rate paid by every borrower?

Tempting claim: A bank altered its input, so the published LIBOR and all LIBOR-linked payments changed by the same amount.

What the recorded basis actually supplies: Historical and later methodologies aggregate selected panel submissions after trimming. The CFTC and DOJ Barclays accounts distinguish trader-oriented attempts, reputation-related lowering, inclusion in the published calculation and some occasions of effect. None of the fourteen sources is a complete daily counterfactual dataset tied to all contracts.

Reason for withholding that conclusion: The path has several steps: submission, ranking and trimming, published setting, chosen currency/tenor, reset date, contract formula and payment. Evidence for the first step does not fill the remainder. Nor does potential trimming prove that all misconduct was harmless; other inputs and coordinated conduct may change which observations remain. The relevant amount and direction depend on the actual setting and contract.

Qualification: Describe the recorded violation or admission precisely, and separately identify any demonstrated published-rate effect. This is an editorial explanation of evidential scope, not a Check result, damages calculation or exoneration.

Reopening condition: Obtain the date-specific submission panel, applicable methodology and an explicitly justified no-misconduct counterfactual; then apply the relevant contract terms and dates. Keep uncertainty in those stages visible.

Original dossier basis: USD panel methodology, 2022–2023 pp. 2–6; CFTC Barclays settlement order pp. 2–6 and p. 4 footnote 2; DOJ Barclays agreement announcement's reputation-related submission discussion; Supreme Court judgment in Hayes and Palombo paragraphs 19–22.

Origin of this passage

Research dossier · E. BEST "WHY NOT?" SPECIMEN · lines 450–462

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

SECOND "WHY NOT?" — A SINGLE METHOD AND END DATE

Why not say that LIBOR was always a guess, ended in June 2023 and was replaced everywhere by SOFR?

Tempting claim: One sentence describes the whole benchmark family, its construction and its replacement.

What the recorded basis actually supplies: Wheatley proposed transaction corroboration; ICE later announced the completed waterfall transition. The retained USD methodology prioritizes transactions while allowing bounded fallback levels. The FCA distinguishes the end of the bank panel from temporary synthetic publication, and its transition page lists different alternatives for different currencies.

Reason for withholding that conclusion: The sentence collapses dates, currencies and methods. A panel-based wholesale funding measure differs from a synthetic Term SOFR-plus-spread calculation. A third-level judgment process differs from a claim that no transaction evidence existed. The final synthetic publication date was 30 September 2024. SONIA, SARON, TONAR and €STR appear alongside SOFR in the retained currency map; none of those labels determines a particular contract's legal fallback by itself.

Qualification: Use a currency/tenor/date/method description and name the milestone meant. The dated FCA description of synthetic use and representativeness is preserved as its own regulatory account; this draft does not supply individual contract advice.

Reopening condition: For a narrower rate or contract claim, identify the applicable historical methodology and actual contract/fallback record. Reopen a general timeline only with evidence addressing the same setting and event, not an undated page carrying the same name.

Original dossier basis: Wheatley reform review printed pp. 7–8 and 28; ICE waterfall transition announcement dated announcement; USD panel methodology, 2022–2023 pp. 1–6; End of the USD bank panel–Living transition summary and currency alternatives dated transition passages.

Origin of this passage

Research dossier · F. SECOND "WHY NOT?" — A SINGLE METHOD AND END DATE · lines 468–480

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

THIRD "WHY NOT?" — UNIVERSAL LEGAL REVERSAL

Why not say that the Supreme Court proved there was no LIBOR misconduct and cancelled the banks' penalties?

Tempting claim: The quashing of Hayes' and Palombo's convictions reverses every LIBOR/EURIBOR finding and proves every institution and submission innocent of wrongdoing.

What the recorded basis actually supplies: The 2025 judgment answers the certified question and explains why the two convictions cannot stand. The historical institutional records concern different legal persons, authorities and procedural forms. Palombo's case concerns EURIBOR, while the dossier's Barclays, UBS and RBS records also have their own currency and temporal bounds.

Reason for withholding that conclusion: The judgment's actual disposition cannot be enlarged to proceedings it does not decide. It identifies serious legal error; that is a substantive result and must be stated plainly. It does not create a universal factual finding that every submission was accurate or rescind the separate orders and agreements catalogued here. Conversely, repeating an earlier allegation or corporate admission does not undo the appellate disposition or justify presenting the quashed convictions as still standing.

Qualification: State the two convictions were quashed, explain the jury-direction issue and attribute each institutional finding or admission to its own record. Do not relabel the judgment as a mere technicality, or the whole prior institutional record as automatically null. The annex's reproduced directions are material under review, not the court's adopted rule.

Reopening condition: A claimed effect on another conviction, settlement or order needs the exact subsequent judicial or administrative instrument addressing that matter. This retained record contains no fresh later-docket search and no blanket rescission instrument.

Original dossier basis: Supreme Court judgment in Hayes and Palombo paragraphs 1–7 and 231–235; procedural terms in CFTC Barclays settlement order, FSA Final Notice to Barclays–DOJ RBS Japan and parent announcement. Connecticut multistate Barclays settlement announcement is a separate 2016 multistate settlement announcement.

Origin of this passage

Research dossier · G. THIRD "WHY NOT?" — UNIVERSAL LEGAL REVERSAL · lines 486–498

Artifact SHA-256: bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e

Attributed research text; this locator does not establish source support or standing.

Sources

14 documentary source candidates · show the source list

Sources

14 research source candidates are carried by this entry, as authored in its research dossier. Each is a research candidate, not an admitted Counterpedia Source.

The dossier records an issuer for 14 of 14 and a date for 14; where it labels no issuer, the card says so. Addresses are shown as recorded. A recorded address is not a Counterpedia capture and does not establish retrieval, authenticity or support for any claim. A card links to a Counterpedia source page only where an accepted record relates a capture of an address recorded for that document to that public source; listing a candidate implies no other association.

Sources by recorded issuer

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All 14 sources selected.

  1. Wheatley reform review

    Issuer
    HM Treasury (The Wheatley Review of LIBOR)
    Selected edition / date
    Published 2012-09-28; cover September 2012; ISBN 978-1-909096-01-1

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Government-commissioned final review and recommendations, not a particular enforcement adjudication or proof of implementation.
    Exact title
    The Wheatley Review of LIBOR: final report
    Selected edition / date
    Published 2012-09-28; cover September 2012; ISBN 978-1-909096-01-1
    Recorded locator
    https://assets.publishing.service.gov.uk/media/5a7b3fe2e5274a319e77e076/wheatley_review_libor_finalreport_280912.pdf
    Technical details
    Research handle in the dossier
    LIB-S01
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  2. ICE waterfall transition announcement

    Issuer
    Intercontinental Exchange / ICE Benchmark Administration
    Selected edition / date
    2019-04-01

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Administrator/company announcement, not an independent audit of every submission.
    Exact title
    ICE Benchmark Administration Successfully Completes the Transition of LIBOR Panel Banks to the Waterfall Methodology
    Selected edition / date
    2019-04-01
    Recorded locator
    https://ir.theice.com/press/news-details/2019/ICE-Benchmark-Administration-Successfully-Completes-the-Transition-of-LIBOR-Panel-Banks-to-the-Waterfall-Methodology/default.aspx
    Technical details
    Research handle in the dossier
    LIB-S02
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  3. USD panel methodology, 2022–2023

    Issuer
    ICE Benchmark Administration Limited (IBA)
    Selected edition / date
    Methodology expressly applicable to panel-bank USD LIBOR from 2022-01-04 through 2023-06-30

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Administrator methodology with express currency, tenor and applicability bounds.
    Exact title
    USD LIBOR Methodology
    Selected edition / date
    Methodology expressly applicable to panel-bank USD LIBOR from 2022-01-04 through 2023-06-30
    Recorded locator
    https://www.ice.com/publicdocs/USD_LIBOR_Methodology.pdf
    Technical details
    Research handle in the dossier
    LIB-S03
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  4. End of the USD bank panel

    Issuer
    Financial Conduct Authority (FCA)
    Selected edition / date
    2023-07-03; describes panel cessation on 2023-06-30

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Dated FCA institutional account of cessation and synthetic-use measures; linked legal notices not separately inspected.
    Exact title
    The US dollar LIBOR panel has now ceased
    Selected edition / date
    2023-07-03; describes panel cessation on 2023-06-30
    Recorded locator
    https://www.fca.org.uk/news/news-stories/us-dollar-libor-panel-has-now-ceased
    Technical details
    Research handle in the dossier
    LIB-S04
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  5. Final synthetic publication

    Issuer
    Financial Conduct Authority; Bank of England; Working Group on Sterling Risk-Free Reference Rates
    Selected edition / date
    2024-10-01; reports final publication on 2024-09-30

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Joint FCA, Bank of England and Sterling Risk-Free Reference Rates Working Group release.
    Exact title
    The end of LIBOR
    Selected edition / date
    2024-10-01; reports final publication on 2024-09-30
    Recorded locator
    https://www.fca.org.uk/news/press-releases/end-libor
    Technical details
    Research handle in the dossier
    LIB-S05
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  6. Living transition summary and currency alternatives

    Issuer
    Financial Conduct Authority (FCA)
    Selected edition / date
    First published 2019-09-02; last update observed 2026-03-09; snapshot at acquisition

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    FCA living institutional summary captured as a 2026 representation.
    Exact title
    About LIBOR transition
    Selected edition / date
    First published 2019-09-02; last update observed 2026-03-09; snapshot at acquisition
    Recorded locator
    https://www.fca.org.uk/markets/libor-transition
    Technical details
    Research handle in the dossier
    LIB-S06
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  7. CFTC Barclays settlement order

    Issuer
    US Commodity Futures Trading Commission (CFTC)
    Selected edition / date
    CFTC Docket 12-25, 2012-06-27

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Administrative order, Docket 12-25, making findings and imposing remedial sanctions on an accepted settlement offer.
    Exact title
    In the Matter of Barclays PLC, Barclays Bank PLC and Barclays Capital Inc. — Order Instituting Proceedings, Making Findings and Imposing Remedial Sanctions
    Selected edition / date
    CFTC Docket 12-25, 2012-06-27
    Recorded locator
    https://www.cftc.gov/idc/groups/public/@lrenforcementactions/documents/legalpleading/enfbarclaysorder062712.pdf
    Technical details
    Research handle in the dossier
    LIB-S07
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  8. CFTC announcement of the same Barclays order

    Issuer
    US Commodity Futures Trading Commission (CFTC)
    Selected edition / date
    CFTC release 6289-12, 2012-06-27

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    CFTC release 6289-12, summarizing its own enforcement action.
    Exact title
    CFTC Orders Barclays to pay $200 Million Penalty for Attempted Manipulation of and False Reporting concerning LIBOR and Euribor Benchmark Interest Rates
    Selected edition / date
    CFTC release 6289-12, 2012-06-27
    Recorded locator
    https://www.cftc.gov/PressRoom/PressReleases/6289-12
    Technical details
    Research handle in the dossier
    LIB-S08
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  9. FSA Final Notice to Barclays

    Issuer
    Financial Services Authority (FSA)
    Selected edition / date
    Notice dated 2012-06-27; FSA reference 122702; URL path includes 2013 but document date is 2012

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Final Notice under section 206, Financial Services and Markets Act 2000; Principles 2, 3 and 5 findings.
    Exact title
    Financial Services Authority — Final Notice to Barclays Bank Plc
    Selected edition / date
    Notice dated 2012-06-27; FSA reference 122702; URL path includes 2013 but document date is 2012
    Recorded locator
    https://www.fca.org.uk/your-fca/documents/final-notices/2013/fsa-final-notice-2012-barclays-bank-plc
    Technical details
    Research handle in the dossier
    LIB-S09
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  10. DOJ Barclays agreement announcement

    Issuer
    US Department of Justice, Office of Public Affairs
    Selected edition / date
    2012-06-27

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Archived DOJ announcement of conditional non-prosecution and admissions; separate agreement attachment not inspected.
    Exact title
    Barclays Bank PLC Admits Misconduct Related to Submissions for the London Interbank Offered Rate and the Euro Interbank Offered Rate and Agrees to Pay $160 Million Penalty
    Selected edition / date
    2012-06-27
    Recorded locator
    https://www.justice.gov/archives/opa/pr/barclays-bank-plc-admits-misconduct-related-submissions-london-interbank-offered-rate-and
    Technical details
    Research handle in the dossier
    LIB-S10
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  11. DOJ UBS Japan and UBS AG announcement

    Issuer
    US Department of Justice, Office of Public Affairs
    Selected edition / date
    2012-12-19

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Archived announcement of subsidiary signed plea agreement, parent NPA and separately charged individuals.
    Exact title
    UBS Securities Japan Co. Ltd. to Plead Guilty to Felony Wire Fraud for Long-running Manipulation of LIBOR Benchmark Interest Rates
    Selected edition / date
    2012-12-19
    Recorded locator
    https://www.justice.gov/archives/opa/pr/ubs-securities-japan-co-ltd-plead-guilty-felony-wire-fraud-long-running-manipulation-libor
    Technical details
    Research handle in the dossier
    LIB-S11
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  12. DOJ RBS Japan and parent announcement

    Issuer
    US Department of Justice, Office of Public Affairs
    Selected edition / date
    2013-02-06

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Archived announcement of subsidiary signed plea agreement and parent deferred prosecution agreement.
    Exact title
    RBS Securities Japan Limited Agrees to Plead Guilty in Connection with Long-Running Manipulation of LIBOR Benchmark Interest Rates
    Selected edition / date
    2013-02-06
    Recorded locator
    https://www.justice.gov/archives/opa/pr/rbs-securities-japan-limited-agrees-plead-guilty-connection-long-running-manipulation-libor
    Technical details
    Research handle in the dossier
    LIB-S12
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  13. Connecticut multistate Barclays settlement announcement

    Issuer
    Office of the Attorney General, State of Connecticut
    Selected edition / date
    2016-08-08

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Attorney General announcement of 44-state settlement, not an adjudication of every borrower loss.
    Exact title
    AG Jepsen: States Reach $100M Settlement with Barclays for LIBOR Manipulation
    Selected edition / date
    2016-08-08
    Recorded locator
    https://portal.ct.gov/ag/press-releases-archived/2016-press-releases/ag-jepsen-states-reach-%24100m-settlement-with-barclays-for-libor-manipulation
    Technical details
    Research handle in the dossier
    LIB-S13
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.

  14. Supreme Court judgment in Hayes and Palombo

    Issuer
    UK Supreme Court
    Selected edition / date
    Judgment delivered 2025-07-23; UKSC/2024/0087

    Open: Recorded locator

    More about this source · 1 recorded address
    Role of this document
    Official retained HTML judgment, [2025] UKSC 29, delivered 23 July 2025; case URL UKSC/2024/0087.
    Exact title
    R v Hayes; R v Palombo — [2025] UKSC 29
    Selected edition / date
    Judgment delivered 2025-07-23; UKSC/2024/0087
    Recorded locator
    https://www.supremecourt.uk/cases/judgments/uksc-2024-0087
    Technical details
    Research handle in the dossier
    LIB-S14
    Research notes
    Dossier notes on this source (opens in a new tab)
    Counterpedia source link
    None: no capture in Counterpedia’s index of captures with accepted source relationships has the exact address recorded for this document.
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Recorded source details. Missing fields are not inferred; selection does not establish support for a claim. Scroll across to compare sources.
DetailWheatley reform reviewICE waterfall transition announcementUSD panel methodology, 2022–2023End of the USD bank panelFinal synthetic publicationLiving transition summary and currency alternativesCFTC Barclays settlement orderCFTC announcement of the same Barclays orderFSA Final Notice to BarclaysDOJ Barclays agreement announcementDOJ UBS Japan and UBS AG announcementDOJ RBS Japan and parent announcementConnecticut multistate Barclays settlement announcementSupreme Court judgment in Hayes and Palombo
Recorded title
  • Exact titleThe Wheatley Review of LIBOR: final report
  • Exact titleICE Benchmark Administration Successfully Completes the Transition of LIBOR Panel Banks to the Waterfall Methodology
  • Exact titleUSD LIBOR Methodology
  • Exact titleThe US dollar LIBOR panel has now ceased
  • Exact titleThe end of LIBOR
  • Exact titleAbout LIBOR transition
  • Exact titleIn the Matter of Barclays PLC, Barclays Bank PLC and Barclays Capital Inc. — Order Instituting Proceedings, Making Findings and Imposing Remedial Sanctions
  • Exact titleCFTC Orders Barclays to pay $200 Million Penalty for Attempted Manipulation of and False Reporting concerning LIBOR and Euribor Benchmark Interest Rates
  • Exact titleFinancial Services Authority — Final Notice to Barclays Bank Plc
  • Exact titleBarclays Bank PLC Admits Misconduct Related to Submissions for the London Interbank Offered Rate and the Euro Interbank Offered Rate and Agrees to Pay $160 Million Penalty
  • Exact titleUBS Securities Japan Co. Ltd. to Plead Guilty to Felony Wire Fraud for Long-running Manipulation of LIBOR Benchmark Interest Rates
  • Exact titleRBS Securities Japan Limited Agrees to Plead Guilty in Connection with Long-Running Manipulation of LIBOR Benchmark Interest Rates
  • Exact titleAG Jepsen: States Reach $100M Settlement with Barclays for LIBOR Manipulation
  • Exact titleR v Hayes; R v Palombo — [2025] UKSC 29
Issuer / publisher
  • IssuerHM Treasury (The Wheatley Review of LIBOR)
  • IssuerIntercontinental Exchange / ICE Benchmark Administration
  • IssuerICE Benchmark Administration Limited (IBA)
  • IssuerFinancial Conduct Authority (FCA)
  • IssuerFinancial Conduct Authority; Bank of England; Working Group on Sterling Risk-Free Reference Rates
  • IssuerFinancial Conduct Authority (FCA)
  • IssuerUS Commodity Futures Trading Commission (CFTC)
  • IssuerUS Commodity Futures Trading Commission (CFTC)
  • IssuerFinancial Services Authority (FSA)
  • IssuerUS Department of Justice, Office of Public Affairs
  • IssuerUS Department of Justice, Office of Public Affairs
  • IssuerUS Department of Justice, Office of Public Affairs
  • IssuerOffice of the Attorney General, State of Connecticut
  • IssuerUK Supreme Court
Documentary role
  • Authority / postureGovernment-commissioned final review and recommendations, not a particular enforcement adjudication or proof of implementation.
  • Authority / postureAdministrator/company announcement, not an independent audit of every submission.
  • Authority / postureAdministrator methodology with express currency, tenor and applicability bounds.
  • Authority / postureDated FCA institutional account of cessation and synthetic-use measures; linked legal notices not separately inspected.
  • Authority / postureJoint FCA, Bank of England and Sterling Risk-Free Reference Rates Working Group release.
  • Authority / postureFCA living institutional summary captured as a 2026 representation.
  • Authority / postureAdministrative order, Docket 12-25, making findings and imposing remedial sanctions on an accepted settlement offer.
  • Authority / postureCFTC release 6289-12, summarizing its own enforcement action.
  • Authority / postureFinal Notice under section 206, Financial Services and Markets Act 2000; Principles 2, 3 and 5 findings.
  • Authority / postureArchived DOJ announcement of conditional non-prosecution and admissions; separate agreement attachment not inspected.
  • Authority / postureArchived announcement of subsidiary signed plea agreement, parent NPA and separately charged individuals.
  • Authority / postureArchived announcement of subsidiary signed plea agreement and parent deferred prosecution agreement.
  • Authority / postureAttorney General announcement of 44-state settlement, not an adjudication of every borrower loss.
  • Authority / postureOfficial retained HTML judgment, [2025] UKSC 29, delivered 23 July 2025; case URL UKSC/2024/0087.
Recorded dates
  • Selected edition / datePublished 2012-09-28; cover September 2012; ISBN 978-1-909096-01-1
  • Selected edition / date2019-04-01
  • Selected edition / dateMethodology expressly applicable to panel-bank USD LIBOR from 2022-01-04 through 2023-06-30
  • Selected edition / date2023-07-03; describes panel cessation on 2023-06-30
  • Selected edition / date2024-10-01; reports final publication on 2024-09-30
  • Selected edition / dateFirst published 2019-09-02; last update observed 2026-03-09; snapshot at acquisition
  • Selected edition / dateCFTC Docket 12-25, 2012-06-27
  • Selected edition / dateCFTC release 6289-12, 2012-06-27
  • Selected edition / dateNotice dated 2012-06-27; FSA reference 122702; URL path includes 2013 but document date is 2012
  • Selected edition / date2012-06-27
  • Selected edition / date2012-12-19
  • Selected edition / date2013-02-06
  • Selected edition / date2016-08-08
  • Selected edition / dateJudgment delivered 2025-07-23; UKSC/2024/0087
Recorded identifiersNot supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.Not supplied in this view.
Recorded locators
Source status
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate
  • research candidate

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Record provenance
research_artifact
{"pack_id":"demo-corpus-wave2","artifact_slug":"libor-methodology-enforcement-transition-demo-corpus-dossier-v0-1","artifact_sha256":"bdefe3c42d801771c8c7976ccc72ab37d068e5f5cd0dfc397d276963e110529e","source_href":"/research/demo-corpus-wave2/libor-methodology-enforcement-transition-demo-corpus-dossier-v0-1","source_kind":"dossier"}
Projection axes
Postureresearch
Source kindresearch_template
Source surfacenot supplied

This renderer preserves upstream distinctions; it does not mint identity, support, authenticity, admission, or truth.

INSPECTCounterpedia Check · this read modelInspect only the signals this renderer actually received
Record identifier
research:demo-corpus-wave2:libor-methodology-enforcement-transition-demo-corpus-dossier-v0-1
Posture
research
Source kind
research_template
Lifecycle
not recorded
Source footprint
not supplied to this presentation
Capture associations
not evaluated here
Unresolved capture identity
not evaluated here
Truth
not a finding of this renderer
Authenticity
not inferred from source or capture presence
Research profile
Demo Corpus
Artifact kind
dossier
Source candidates
14
CHECK is inspection, not a truth badge. Source presence ≠ support; capture association ≠ authenticity; rendering ≠ admission.