Three regulatory agencies in the United States and one in the United Kingdom filed and settled charges against Deutsche Bank AG and one subsidiary related to their alleged systematic manipulation of London Interbank Offered Rate and foreign exchange benchmarks on numerous occasions from 2003 through 2011. As a result of such actions, Deutsche Bank agreed to pay aggregate fines in excess of US $2.5 billion. The four government agencies—the US Commodity Futures Trading Commission, the US Department of Justice, the New York State Department of Financial Services and the UK Financial Conduct Authority—alleged that the bank often considered its own proprietary positions when making the bank’s submissions to LIBOR and Euro Interbank Offered Rate benchmarks. On occasion, charged the regulators, Deutsche Bank traders also helped traders at other banks manipulate LIBOR for US Dollar, Japanese Yen, UK Sterling, Swiss Franc and Euribor for their firms’ benefit too. The CFTC claimed that, “Deutsche Bank’s traders were able to accommodate and facilitate the attempts to manipulate LIBOR and Euribor for years because Deutsche Bank lacked internal controls, procedures and policies concerning LIBOR and Euribor submission processes, and failed to adequately supervise its trading desks and traders.” According to the CFTC, the bank’s problematic conduct continued even after it requested Deutsche Bank to review its US Dollar LIBOR submission practices in April 2010. In connection with resolving this matter, Deutsche Bank entered into a deferred prosecution agreement with the US Department of Justice. The New York State Department of Financial Services also ordered the bank to terminate seven non-US-based employees who are still employed by it, but who participated in the alleged misconduct (ten employees were previously terminated by the bank for their wrongful conduct). The Financial Conduct Authority also criticized Deutsche Bank for not cooperating fully with its investigation. According to the CFTC’s complaint, Deutsche Bank’s alleged wrongful conduct occurred in its offices in London, Frankfurt, New York, Tokyo and Singapore.