FSA: Final Notice Barclays – LIBOR Submissions

FSA approach to risk management and the role of Compliance

Key findings - systems and controls

No specific systems and controls regarding LIBOR submissions process in place at relevant time.

Particularly:

• no policy in place giving guidance on the importance of the integrity of the process for determining LIBOR;
• no training to submitters about submissions process;
• no formal monitoring of submissions made;
• no review of integrity of submissions process;
• no identification of LIBOR submissions as an area of significant risk; and
• no clear lines of responsibility for systems and controls.

Also once policy put in place:

• no setting out or reference to relevant BBA guidelines;