Overview

Plaintiffs allege that Defendants, between January 1, 2006 and June 30, 2011, manipulated or helped manipulate Yen-LIBOR, EuroYen TIBOR, and the prices of EuroYen-Based Derivatives. Panel banks that made the daily Yen-LIBOR and/or Euroyen TIBOR submissions to the British Bankers’ Association and Japanese Bankers Association (collectively, “Contributor Bank Defendants”), such as Citi and HSBC, allegedly falsely reported their cost of borrowing in order to financially benefit their Euroyen-Based Derivatives positions. Contributor Bank Defendants also requested that other Contributor Bank Defendants make false Yen-LIBOR and Euroyen TIBOR submissions on their behalf to benefit their Euroyen-Based Derivatives positions. 

Plaintiffs further allege that inter-dealer brokers, intermediaries between buyers and sellers in the money markets and derivatives markets (the “Broker Defendants”), such as RP Martin, had knowledge of and assisted the Contributor Bank Defendants’ alleged manipulations of Euroyen-Based Derivatives, in violation of the Commodity Exchange Act. For example, Contributor Bank Defendants used the Broker Defendants to manipulate Yen-LIBOR, Euroyen TIBOR, and the prices of Euroyen-Based Derivatives by disseminating false “Suggested LIBORs,” publishing false market rates on broker screens, and publishing false bids and offers into the market.

EuroYen Based Derivatives Are

EuroYen TIBOR futures contract on the Chicago Mercantile Exchange (“CME”), Tokyo Financial Exchange (“TFX”), Singapore Exchange (“SGX”), or London International Financial Futures & Options Exchange (“LIFFE”) entered into by a US person, or by a person from or through a location within the US; a Japanese Yen currency futures contract on the CME; a Yen
​LIBOR-and/or EuroYen TIBOR-based interest rate swap entered into by a US person, or by a person from or through a location within the US; an option on a Yen LIBOR-and/or EuroYen TIBOR-based interest rate swap (“swaption”) entered into by a US person, or by a person from or through a location within the US; and a Yen LIBOR-and/or EuroYen TIBOR-based forward rate agreement entered into by a US person, or by a person from or through a location with the US.

Class

All Persons that purchased, sold, held, traded, or otherwise had any interest in any Euroyen-Based Derivatives during the period of January 1, 2006 through June 30, 2011 (“Class Period”). Excluded from the Class are Defendants and their parents, subsidiaries, affiliates, or agents; the Released Parties (as defined in the Agreements); and any Class Member who files a timely and valid request for exclusion.

Defendants
Contributor Bank Defendants
  • Bank of Tokyo-Mitsubishi UFJ, Ltd.
  • Bank of Yokohama, Ltd.
  • Barclays Bank PLC
  • Citibank Japan Ltd.
  • Citibank, NA
  • Citigroup Global Markets Japan, Inc.
  • Citigroup Inc.
  • Deutsche Bank AG
  • HSBC Bank PLC
  • HSBC Holdings PLC
  • ICAP Europe Ltd.
  • JP Morgan Chase & Co.
  • JP Morgan Chase Bank, National Association
  • JP Morgan Securities Plc.
  • Lloyds Banking Group PLC
  • Martin Brokers (UK) Ltd.​
  • Mitsubishi UFJ Trust & Banking Corporation
  • Mizuho Corporate Bank, Ltd.
  • Norinchukin Bank
  • Rabobank
  • RBS Securities Japan Ltd.
  • Royal Bank of Scotland Group
  • Royal Bank of Scotland Group PLC
  • RP Martin Holdings Ltd.
  • Shinkin Central Bank
  • Shoko Chukin Bank, Ltd.
  • Societe Generale SA
  • Sumitomo Mitsui Banking Corporation
  • Sumitomo Trust & Banking Co., Ltd.
  • Tullett Prebon PLC
  • UBS AG
  • UBS Securities Japan Co., Ltd.


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Broker Defendants

  • Barclays Plc.
  • Bank of America Corporation
  • Bank of America, NA
  • Bank of Tokyo-Mitsubishi UFJ, Ltd.
  • Bank of Yokohama, Ltd.
  • Barclays Bank Plc.
  • Barclays Capital Inc.
  • Citibank Japan, Ltd.
  • Citibank, NA
  • Citigroup Global Markets Japan, Inc.
  • Citigroup, Inc.
  • DB Group Services UK Ltd.
  • Deutsche Bank AG
  • HSBC Bank Plc.
  • HSBC Holdings Plc.
  • ICAP Europe Ltd.
  • ICAP Plc.
  • JP Morgan Chase & Co.
  • JP Morgan Securities Plc.
  • JPMorgan Chase Bank, National Assoc.
  • Lloyds Bank Plc.
  • Lloyds Banking Group Plc.
  • Martin Brokers (UK), Ltd.
  • Merrill Lynch International
  • Mitsubishi UFJ Trust & Banking Corp.
  • Mizuho Bank, Ltd.
  • Mizuho Corporate Bank, Ltd.
  • Mizuho Trust & Banking Co., Ltd.
  • Norinchukin Bank
  • Rabobank
  • RBS Securities Inc.
  • RBS Securities Japan Ltd.
  • Resona Bank, Ltd.
  • Royal Bank of Scotland Group Plc.
  • Royal Bank of Scotland Plc.
  • RP Martin Holdings, Ltd.
  • Shinkin Central Bank
  • Shoko Chukin Bank, Ltd.
  • Societe Generale SA
  • Sumitomo Mitsui Banking Corp.
  • Sumitomo Trust & Banking Co., Ltd.
  • Tullett Prebon Plc.
  • UBS AG
  • UBS Securities Japan Co. Ltd.

Preliminary Settlements
​$148,000,000
​Deutsche Bank AG ​$77,000,000
​JPMorgan Chase & Co.​ ​$71,000,000

 

Earlier Settlements
​Citibank ​$23,000,000
​HSBC ​$35,000,000

 

Filing Deadline: Contact SRG​
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