On Tuesday, June 20, the UK Serious Fraud Office (“SFO”) announced charges against Barclays Plc and four former executives for conspiracy to commit fraud and provision of unlawful financial assistance in violation of the Companies Act 1985. These charges relate to Barclay Plc’s capital raising arrangements with Qatar Holding LLC and Challenger Universal Ltd in June and October 2008, as well as to a $3 billion loan facility made available to the State of Qatar acting through the Ministry of Economy and Finance in November 2008. According to the SFO press release, the investigation was first announced in 2012, and the individuals charged include a former Chief Executive Officer of Barclay Plc, a former Executive Chairman of Barclay Capital Investment Banking and Investment Management in Middle East and North Africa, a former Chief Executive of Barclay Wealth and Investment Management, and a former European Head of Barclay Plc’s Financial Institutions Group.

While no US-based charges have been announced, the SFO’s announcement comes on the heels of Barclays Plc’s March 2017 disclosure to the SEC in which the company stated that “the DOJ and SEC are undertaking an investigation into whether the Group’s relationships with third parties who assist Barclays Plc to win or retain business are compliant with the U.S. Foreign Corrupt Practices Act.”