US regulators have been much harsher than their UK counterparts while European authorities have been even kinder...

Oliver Gill
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Six of the 12 lenders fined by US authorities for interest rates and foreign exchange manipulation were from the UK

US regulators have slapped fines on banks at four times the level imposed by their UK counterparts in connection with interest rate and foreign exchange manipulation.

A total of 12 banks have been fined $9.8bn (£7.7bn) by US authorities over the last four and a half years. This compares with £2bn imposed on 11 lenders by UK authorities.

Meanwhile, on the continent the European Commission and individual regulators were even more lenient – levying a total of €1.7bn across 10 banks according to data prepared by law firm Collyer Bristow.

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Substantial fines either have been or are likely to be levied on global lenders for activities other than in relation to interest rates and foreign exchange manipulation. One example is the $14bn Deutsche Bank is facing for the activities of its residential mortgage-backed securities division in the years leading up to the global financial crisis.

However, the bank which has been forced to pay out the most simply in relation to interest rates and FX by various regulators is Barclays: its individual tally totalled £723m since June 2012.

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UBS was hit with the largest fines in relation to manipulating multiple interbank rates and FX – these totalled £1.1bn. Within this total, however, the Swiss lender's home regulator, Finma, only fined the banks SFr59m (£46.1m).

Of the 12 lenders fined by either Commodity Futures Trading Commission, Department of Justice or the Federal Reserve in the US, six were from the UK, including HSBC, RBS, Lloyds and Barclays.

“Clearly, the US system is much tougher on those that are found to transgress compared to the UK and European regulators,” said Collyer Bristow’s head of the banking and financial disputes Stephen Rosen.

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