Benchmark submission rigging

Benchmark submission rigging is skewing the figures a panel member reports into a reference rate calculation, so that the published benchmark moves in favour of positions that settle against it.

Also called rate rigging, benchmark manipulation. Observed in bonds, swaps, futures, fx. One of the benchmark and cross-market manipulation techniques. 32 enforcement actions in the library.
Updated 2026-09-07

How does benchmark submission rigging work?

Some benchmarks are not measured. They are asked for.

A submission-based benchmark is calculated from figures that panel members report — typically an estimate of the rate at which the institution could borrow, or the price at which it could transact — rather than from observed trades. An administrator collects the submissions, discards the highest and lowest, averages the rest, and publishes the result as an official rate. Contracts worldwide then settle against that number.

The vulnerability is immediate. The person supplying the input works at an institution that also holds positions settling against the output.

The mechanic has four steps.

1. Hold a position that references the benchmark. A swap book, a futures position, a portfolio of floating-rate instruments — anything whose value on a fixing date depends on where the benchmark prints.

2. Ask the submitter for a direction. In the charged cases this was frequently done in writing, and often in terms as plain as asking for a high or low print on a particular day.

3. Submit a skewed figure. The submission need not be absurd. It needs to survive the trim and pull the average — a fraction of a basis point is enough when the notional base is large.

4. Collect on the derivative. The published fix determines the payments, and the position pays off. No trade in any market was required.

Where several institutions coordinate, the trimming defence disappears entirely: if enough submissions move together, the trim removes only the honest outliers.

A worked example with real numbers

A desk holds a swap position with $12 billion of notional exposure on which it receives floating against a benchmark, resetting on a single fixing date. One basis point on that notional, for a three-month period, is worth:

$12,000,000,000 × 0.0001 × (90/360) = $300,000

Now consider the submission arithmetic. Sixteen panel banks submit; the top four and bottom four are discarded; the middle eight are averaged.

Acting alone, the bank moves the published rate by 0.00125% — an eighth of a basis point. Applied to the position:

$12,000,000,000 × 0.0000125 × (90/360) = $37,500

Thirty-seven thousand dollars, from one submission on one day. Unremarkable in isolation, which is exactly the problem: no individual instance looks worth prosecuting, and a submission a basis point away from an honest estimate is not obviously wrong at all, because the honest estimate was itself a judgement.

Repeat it across many fixing dates, many currencies and many tenors, and the aggregate becomes substantial. Coordinate with three other panel members and the per-day figure rises fourfold while each individual submission becomes less conspicuous, since the submissions no longer diverge from one another.

That structure — small, deniable, repeated, and improved by collusion — is why the conduct persisted for years and why the eventual penalties were measured in billions rather than in the sums any individual trade generated.

Why is benchmark submission rigging illegal?

It is illegal as false reporting, as fraud, and where coordinated, as an agreement between competitors affecting price.

False reporting. The Commodity Exchange Act makes it unlawful to deliver false or misleading reports concerning market information that affects or tends to affect the price of a commodity. A submission is precisely such a report, and its falsity does not depend on proving that the published rate was artificial — only that the reported figure was not what the submitter believed.

Fraud-based manipulation. CFTC Rule 180.1 and § 6(c)(1) reach manipulative and deceptive devices in connection with swaps and commodity contracts. Because the rule is modelled on Rule 10b-5, the question is deception rather than artificiality, which is the more tractable question here.

Criminal fraud. Wire fraud under 18 U.S.C. § 1343 was the workhorse in criminal cases, since submissions travelled by wire and the scheme deprived counterparties of money through deception. Section 1348 was also charged. Prosecutions were brought in several jurisdictions, with outcomes that varied considerably — a number of convictions were subsequently overturned on appeal, and the divergence between institutional settlements and individual criminal outcomes is one of the defining features of this enforcement wave.

Competition law. Where submitters at competing institutions agreed on the direction of their submissions, the conduct engages the Sherman Act in the United States and equivalent prohibitions elsewhere. This is an independent theory: an agreement between competitors about a price input is unlawful whether or not it succeeded.

Regulatory offences. In the United Kingdom and the European Union, benchmark administration and contribution became regulated activities in their own right after the fact, with dedicated offences attached.

Which real enforcement actions have alleged benchmark submission rigging?

This library holds 32 enforcement actions tagged benchmark submission rigging. The table shows the largest by civil penalty together with the most recently filed. Every row links to a page carrying the regulator's own release and, where one was published, the complaint.

All 32benchmark submission riggingactions →

How does benchmark submission rigging get detected?

This is the manipulation technique that surveillance was worst at finding and that documents were best at proving.

Submission-versus-observable-cost analysis. Compare each panel member’s submissions against their own observable funding transactions, their certificate of deposit issuance, and their peers’ submissions. A submitter reporting a rate their own market activity contradicts is the statistical starting point — though in stressed conditions with few transactions, this comparison is weak, which is why it did not detect the conduct at the time.

Position-direction correlation. For each fixing date, compute the firm’s net exposure to the benchmark and test whether the direction of its submission relative to the panel correlates with the direction that exposure required. Across enough dates this becomes very difficult to explain.

Communications review. The decisive evidence. Requests from traders to submitters, and messages between submitters at different institutions, converted an argument about reasonable estimates into a documentary record of intent. Nearly every major case rested on it.

Submission dispersion analysis. Coordinated submissions become less dispersed than independent ones. Unusually tight clustering among a subset of panel members, sustained over time, is a signature of coordination rather than of accuracy.

Structural review. Regulators examined whether the submission function was separated from trading at all. In many institutions it was not — submitters and traders sat on the same desk, which was treated as a control failure independent of any specific submission.

• Submissions that diverge from the submitter's own observable funding costs or transaction prices.
• Correlation between a submission's direction and the firm's derivative position on that fixing date.
• Communications between traders and submitters, or between submitters at different panel banks.
• Submissions clustering at the edge of the trimmed range, where a single value can still influence the average.
• Submission patterns that change abruptly when a trader joins or leaves a desk.

What penalties does benchmark submission rigging actually attract?

The numbers below are computed from this site's own case records at build time, not quoted from a secondary source. They change whenever a new action is added to the library.

What are the red flags?

• A benchmark built on estimates rather than observed transactions.
• Panel members with large derivative books referencing the benchmark they submit to.
• No separation, physical or reporting, between the submission function and the trading desk.
• A published rate that moves less than the underlying market it is meant to describe.

The structural red flag is the one that matters and the one that was visible in advance: a benchmark whose inputs are estimates supplied by parties with positions in the output. That design flaw was described in the academic literature before it was described in an indictment.

What benchmark submission rigging is not

It is not an inaccurate estimate. A submission is a judgement, and judgements can be wrong. The offence requires that the figure submitted was not the submitter’s honest view.

It is not hedging. A bank with exposure to a benchmark may hedge it freely. What it may not do is move the benchmark instead.

It is not the same as trading around a fix. Trading in the underlying market during a fixing window is a different technique, addressed on the pages for FX fixing and settlement price manipulation. Submission rigging requires no trade at all, which is what made it so cheap and so hard to see.

Frequently asked questions about benchmark submission rigging

What techniques are related to benchmark submission rigging?

• FX fixing — FX fixing manipulation is trading during the short window used to calculate a daily currency benchmark, using advance knowledge of client orders that must be executed at that fix.
• Settlement price manipulation — Settlement price manipulation is trading to move an official settlement price, because that price determines margin, portfolio marks and the payoff on contracts many times larger than the trading itself.
• Cash versus derivatives schemes — A cash versus derivatives scheme establishes a large derivative position and then trades the smaller underlying market at a deliberate loss, in order to move the reference price the derivative settles against.
• Banging the close — Banging the close is trading heavily during the short window used to calculate a settlement price, in order to move that settlement in favour of a much larger position that references it.

Terms defined on this page

Benchmark · Submission Based Benchmark · Libor · Fixing · Swap · Collusion · Chat Surveillance

Sources

1. CFTC Rule 180.1 — Electronic Code of Federal Regulations
2. Commodity Exchange Act § 9 — manipulation and false reporting — Cornell Legal Information Institute
3. IOSCO Principles for Financial Benchmarks — International Organization of Securities Commissions
4. Alternative Reference Rates Committee — SOFR — Federal Reserve Bank of New York

Reviewed September 7, 2026. Every statute link points at the primary text. If something here is wrong, tell us — corrections are logged in public.