Barclays Bank Plc

On 23 September 2014, the Authority imposed a financial penalty of £37,745,000 on Barclays Bank plc (Barclays) for breaches of Principles 3 (Management and Control) and 10 (Clients' Assets) of the Authority's Principles for Businesses (the Principles) and associated Client Asset Rules (CASS) in the FCA's Handbook. Barclays agreed to settle at an early stage of the Authority's investigation. Barclays therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £53,921,619 on Barclays. Barclays failed to adequately protect approximately £16.5 billion of clients' safe custody assets between 1 November 2007 and 24 January 2012 (the Relevant Period). The Authority found significant deficiencies in Barclays' systems and controls in the opening, on-going operation and monitoring of external safe custody accounts, and failures in arranging adequate protection for certain of the safe custody assets for which it was responsible. Specifically, in relation to its safe custody assets arrangements in its Investment Banking Division, during the Relevant Period Barclays breached: a) Principle 3: by failing to take reasonable care to organise and control its affairs responsibly with adequate risk management systems in order to ensure that it: i. had in place adequate organisational arrangements in respect of safe custody assets; and ii. implemented and maintained adequate policies and procedures to detect and manage its safe custody asset risks. b) Principle 10: by failing to arrange adequate protection for safe custody assets when it was responsible for them. Barclays' failings also meant that it breached CASS 1A.2.8R, 6.2.1R, 6.2.2R, 6.3.1R, 6.5.1R, 6.5.2R and 6.5.6R. As a consequence of Barclays' breaches its' clients were at risk of incurring extra costs, lengthy delays or losing their assets if Barclays had become insolvent during the Relevant Period. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2014/barclays-bank-plc-sept-2014