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Harry Cassin
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Andy Spalding
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Jessica Tillipman
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Bill Steinman
Senior Editor

Richard L. Cassin
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Elizabeth K. Spahn
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
Contributing Editor

A Haiku disclosure from Barclays

London-based Barclays Bank had very little to say in its latest SEC filing about an ongoing FCPA investigation by the DOJ and SEC.

The minimalist statement Tuesday was just 76 words, among the briefest FCPA disclosures on record.

(In their latest FCPA disclosures, Halliburton used 300 words, Goodyear 186, and NCR 433.)

Barclay’s first disclosed the U.S. investigation in a filing with the London Stock Exchange on October 31 last year.

In August last year, the U.K. Serious Fraud Office announced an investigation into Barclays. It said, ‘On 15 August 2012 the Director of the SFO formally opened an investigation into certain commercial arrangements between Barclays Bank and Qatar Holdings in 2008.’

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Here’s the full FCPA disclosure from the Form 6-K (Report of Foreign Private Issuer) from Barclays PLC and Barclays Bank PLCI filed with the SEC on February 12:

On October 2012 Barclays was informed by the US Department of Justice and the US Securities and Exchange Commission that they had commenced an investigation into whether the Group’s relationships with third parties who assist Barclays to win or retain business are compliant with the United States Foreign Corrupt Practices Act. Barclays is co-operating with all the authorities fully. It is not possible to estimate the financial impact upon Barclays should any adverse findings be made.

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