Libor Litigation and the Role of Screening: The Need for Enhanced Compliance Programs

The U.S. Department of Justice, the Securities and Exchange Commission, and other regulatory agencies have recently made allegations of a possible conspiracy to manipulate the U.S. dollar Libor rate (“Libor”) by several major banks. These allegations followed the application of empirical methods known as screens to flag unexpected patterns in the Libor.Screens use commonly available data such as prices, costs, market shares, bids, transaction quotes,