
The Department's investigation found that Barclays, through its employees and agents, misappropriated confidential information provided to Barclays by HP in regard to FX options and spot transactions, and deceived HP about the nature of its trading, in violation of duties to HP, as described in the indictment returned in United States v. Bogucki, 18-CR-00021 (N.D. Cal.). Specifically, Barclays FX traders (1) traded ahead of large HP spot and options purchases in August 2011, increasing the price that HP paid to Barclays; (2) manipulated the "Bloomberg fix" by purchasing British pounds in a manner which increased the profits of individual Barclays traders; (3) traded ahead of HP's "unwind" of options in September and October 2011, decreasing the price that HP ultimately received from Barclays; and (4) actively deceived HP about the causes of market movements during this period.