Barclays, Staley and Maxwell: two records, one…

Barclays now appears in the public record on two separate planes. The first concerns Jes Staley and the bank’s governance: in 2025, the UK Upper Tribunal found that its former chief executive had knowingly approved two inaccurate statements that risked misleading the Financial Conduct Authority. The second concerns Ghislaine Maxwell: US Department of Justice documents analysed by Reuters indicate that she held $2.4 million at Barclays at the end of 2018 and that more than $600,000 was later transferred from that account to UBS in the three weeks after Jeffrey Epstein’s arrest. These two findings do not prove that Epstein himself held an account at Barclays. Upper Tribunal, decision released 26 June 2025 · Reuters, 27 March 2026

That boundary is essential. The Staley ruling concerns the accuracy of a response sent to a regulator and the integrity of a senior manager. The Reuters investigation concerns an account held by another person, Ghislaine Maxwell, who was convicted in the United States and is legally distinct from Epstein. Placing these records on the same timeline can illuminate Barclays’ controls. Merging them into a single accusation would produce a conclusion that the sources do not support. Upper Tribunal, paragraphs 496 to 503 · Ghislaine Maxwell criminal judgment, SDNY, 29 June 2022

The comparison with other banks is covered in our investigation into the signals financial institutions could see. Deutsche Bank’s commercial exception mechanism is examined in a separate analysis. The question here is narrower: what did Barclays verify, whom did the bank rely on, and what does the Maxwell account now reveal?

The amounts do not describe the same thing as the Staley sanction. They should neither be added together nor presented as proof of an account or flows belonging to Epstein at Barclays.

First plane: an assurance built around Staley

On 15 August 2019, the FCA asked Barclays for written assurance: had the board sufficiently informed itself, and was it satisfied with any association between Jes Staley or Barclays and Jeffrey Epstein? The question was not limited to possible knowledge of the crimes. The Tribunal found that it also concerned the nature of the association and the checks conducted by the bank. Upper Tribunal, paragraphs 318 to 371

Several Barclays officials prepared the response using conversations with Staley and documents assembled during the summer of 2019. The Tribunal found that, by 8 October, the bank did not have a complete and accurate picture of the relationship. It did not know, among other things, its depth, the frequency of contact after Epstein’s conviction, or that the contact continued until late October 2015. This finding does not mean that the board knew the letter was false. It means that the information it received from Staley was incomplete and differed from the judges’ later assessment. Upper Tribunal, paragraphs 316 and 317

On 1 October, a first draft stated that Barclays’ financial crime team had reviewed the bank’s records and found no client relationship with Epstein or his “known affiliates”. The reference to affiliates disappeared from the final text. The letter that was sent said only that the review had found no client relationship with Epstein. The public record establishes this edit, but not its reason or author. Upper Tribunal, paragraphs 405 to 433

That negative finding must be read literally. It was the stated result of a review of Barclays’ records. It supports neither a claim that the method was exhaustive nor the invention of an account that was not found. The public ruling does not list the names, entities, spelling variants, counterparties, periods or databases that were checked. Upper Tribunal, letter text and paragraphs 405 to 433

The Tribunal distinguished Barclays' knowledge from Staley's. It found that Staley was the only participant in preparing the letter with direct knowledge of the true nature of his relationship with Epstein.

Circular validation in the emails

On 6 October, Barclays’ general counsel Bob Hoyt sent the nearly final draft to Staley and asked whether its language was “fair and accurate”. The two spoke for about five minutes the next day. The Tribunal accepted Hoyt’s account: he told Staley that only Staley knew the facts and had to decide whether the wording was appropriate. At 12:37 pm, Hoyt wrote to Higgins that Staley had reviewed the letter and was comfortable with its language. The only change then attributed to Staley concerned the tense of a sentence unrelated to the two disputed statements. Higgins sent the text on 8 October. Upper Tribunal, paragraphs 422 to 433

The control weakness is specific: Barclays officials believed the relationship was not close because Staley had described it that way, then asked Staley to certify that a summary derived from his own account was accurate. Hoyt said that he did not know about the emails that emerged later and relied on Staley’s judgment to characterise the relationship. Higgins testified that, with the information later known, Barclays would probably have responded differently, might not have sent a letter, or might have opened a discussion with the FCA. Upper Tribunal, paragraphs 475 and 476

In November 2019, JPMorgan told the FCA that it had identified documents in the course of US investigations. The FCA then compelled the bank to produce the exchanges. The record includes more than 1,200 emails between 2008 and 2012. Those emails concern the JPMorgan period, not banking services supplied by Barclays. They illuminate what Staley knew about his own relationship and what he had not described to Barclays. Upper Tribunal, paragraphs 7, 105 and 434

On 26 June 2025, the Tribunal found that Staley knew the two statements were inaccurate, understood the risk of misleading the FCA and acted without integrity in approving them. The FCA’s final notice dated 23 July 2025 set the fine at £1,107,306.92 and barred him from senior management or significant-influence functions in UK regulated financial activities. These are personal sanctions against Staley, not a fine imposed on Barclays. Upper Tribunal, paragraphs 496 to 503 and 559 to 561

The decision answers two questions: the closeness of the relationship and the date of the last contact. It does not find that Staley participated in Epstein’s crimes, nor does it find that the Barclays board knew the letter was false. When Staley stepped down on 1 November 2021, Barclays stressed that the regulators’ preliminary findings did not say he had seen or known about Epstein’s crimes. That limit does not alter the later conclusion about the letter. Barclays, 1 November 2021 statement filed with the SEC · Upper Tribunal, paragraphs 473 to 503

Second plane: a Barclays account in Maxwell’s name

The second plane rests on a Reuters investigation published on 27 March 2026. The reporters examined files made public by the US Department of Justice, banking exchanges and a 2020 wealth report prepared for the federal court in Manhattan by accountants hired by Maxwell’s lawyers. According to that analysis, Barclays was, from 2017, the only institution outside the United States where Maxwell held funds. She held $2.4 million there at the end of 2018. Reuters, 27 March 2026

Reuters also reported that, in the three weeks after Epstein’s arrest on 6 July 2019, UBS received more than $600,000 from Maxwell’s Barclays account. The exchanges reviewed indicate that she was gathering money to pay a credit-card bill. This wording documents the immediate banking origin and destination of the transfers. It establishes neither the ultimate economic origin of each dollar nor whether the funds were lawful or unlawful. Reuters, 27 March 2026

The account cannot be described as Epstein’s account. The reported holder was Maxwell. Proximity between two people, even where one was convicted in a related criminal case, does not erase their separate legal identities or the evidentiary requirements attached to a bank account. No public source examined for this article establishes that Epstein was a Barclays customer or that an account was opened in his name. Reuters, 27 March 2026 · Upper Tribunal, text of the 8 October 2019 letter

That caution does not cancel the compliance questions. Maxwell had been publicly associated with Epstein well before 2017. The material now published therefore permits questions about Barclays’ onboarding, risk classification, monitoring and response after Epstein’s arrest. In its current public form, it does not provide the account’s exact opening or closing date, the relevant Barclays entity, the contents of the customer due-diligence file, any alerts or the decisions made about the transfers to UBS. Reuters, 27 March 2026

The records review described in the 2019 letter makes the issue more concrete. The first draft mentioned Epstein and his known affiliates, while the final version named only Epstein. The public record does not say whether Maxwell was searched by name, whether she fell within the intended category, or whether her account was connected to the review concerning the chief executive. This absence of information does not prove that she was omitted. It simply prevents a claim that she was included. Upper Tribunal, paragraphs 405 to 433 · Reuters, 27 March 2026

Investor litigation narrows without a liability ruling

In Merritt v. Barclays, investors brought a putative class action concerning New York-listed ADRs and London-listed ordinary shares bought between 22 July 2019 and 12 October 2023. On 10 July 2025, the federal court in California allowed several US-law claims to move beyond the pleading stage, while finding the claim under section 90A of UK law insufficiently pleaded. At that stage, the judge was required to treat properly pleaded allegations as true without finding that they had been proved. C.D. California, amended order dated 10 July 2025

On 28 July 2026, the same judge dismissed the revised UK claim without leave to amend. The order required the plaintiffs to file a third amended complaint omitting that claim alone and expressly said that the federal Exchange Act claims continued to be litigated. The dismissal of the UK claim is therefore neither a finding of liability against Barclays nor the documented end of the entire case. C.D. California, docket 160 order dated 28 July 2026

Political pressure in 2026 targets the board’s method

On 22 July 2026, Senator Elizabeth Warren and Representatives Ro Khanna and Raja Krishnamoorthi sent eight groups of questions to Barclays chair Nigel Higgins. They asked, among other things, which checks preceded Staley’s recruitment, who drafted and approved the 2019 letter, why the full board was not consulted, what disciplinary measures were considered, and whether US banking regulators had contacted Barclays after the new DOJ releases. The letter requested a response by 5 August. These congressional questions are not judicial findings. Letter dated 22 July 2026 · Congressional press release, 23 July 2026

On 23 July, Barclays told Reuters that it had investigated on the basis of the information then available and noted that the UK regulator had found that Staley misled the bank. Barclays added that new information had since emerged concerning activities before he joined the bank. This position is consistent with the Tribunal’s finding that Barclays lacked a complete picture in 2019. In the sources identified by 9 August, it does not publicly answer the detailed questions about recruitment, the scope of the records review or the Maxwell account. Reuters, 23 July 2026 · Upper Tribunal, paragraphs 316 and 317

Eight public questions that remain open

The documents support precise questions without presuming their answers. The people and institutions named below may hold some or all of the information. Banking secrecy, employment law, investigative confidentiality or other duties may also prevent them from publishing it. Their silence would confirm no hypothesis.

Which checks preceded Staley’s recruitment in 2015? Barclays and the members of its nomination committee at the time could specify the questions asked about his relationship with Epstein, the independent references sought and the written declarations obtained. The 22 July congressional letter already asks Barclays to release this material. Congressional letter, questions 1 and 2
Why did the 2019 assurance rely mainly on Staley to characterise his own relationship? Nigel Higgins, Bob Hoyt, Crawford Gillies and the board records could document which independent checks were considered, performed or rejected. The FCA and PRA could clarify the expectations communicated to the bank, subject to their confidentiality rules. Upper Tribunal, paragraphs 318 to 433
Who proposed and approved the removal of “known affiliates” between the 1 October draft and the final letter? Versions and emails held by Barclays, together with FCA records, could provide a chronology. The change is established; its reason is not. Upper Tribunal, paragraphs 405 to 433
What was the exact scope of the records review? Barclays could identify, in redacted form, the names, entities, variants, counterparties, periods and systems searched. The FCA could say whether it tested or audited that method. The Tribunal published the stated result, not the complete protocol. Upper Tribunal, letter text and paragraphs 405 to 433
Did the 2019 review include Ghislaine Maxwell and her account? Barclays is best placed to answer. The FCA could clarify whether it asked for a search of people closely associated with Epstein. An answer should distinguish the existence of an account, its risk classification and any alerts without exposing unnecessary personal data. Reuters, 27 March 2026 · Upper Tribunal, paragraphs 405 to 433
When was the Maxwell account opened, reassessed and closed? Barclays could publish a redacted chronology naming the relevant entity, review dates and decisions taken after Epstein’s arrest. The DOJ documents and wealth report cited by Reuters could supplement that chronology if they are published in indexed and redacted form. Reuters, 27 March 2026
How were the transfers of more than $600,000 to UBS reviewed? Barclays and UBS could describe the controls applied without revealing any SAR, whose existence or absence must not be inferred. The relevant authorities could say whether the movements were included in a regulatory review. Reuters documents the transfers, not Barclays’ compliance reasoning. Reuters, 27 March 2026
Did Barclays answer the US lawmakers by 5 August, and will that response be published? Nigel Higgins, Elizabeth Warren, Ro Khanna and Raja Krishnamoorthi could release a redacted response or state its status. As of 9 August 2026, no detailed public response was identified in the sources consulted for this article. Congressional letter, page 5

One institution, two standards of proof

The Staley record shows a bank that questioned its chief executive, reviewed its records and answered the regulator, but did not have a complete account of the relationship it was assessing. The Tribunal placed regulatory responsibility on Staley: he knew the facts, approved the two statements and knew they could mislead the FCA. The governance question remains because Barclays’ method allowed the subject of the review to become the principal source validating his own account. Upper Tribunal, paragraphs 316, 317 and 473 to 503

The Maxwell account opens a different field. It does not make Barclays “Epstein’s bank”. It documents a banking relationship with a person closely associated with Epstein, $2.4 million present at the end of 2018 and more than $600,000 transferred to UBS after the July 2019 arrest. The rigorous question is not whether the account holder’s name can be changed. It is how the account was accepted, monitored, connected to known risk and handled when the context changed. Reuters, 27 March 2026

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Sources

Limitations

The Upper Tribunal decision concerns Staley’s conduct and his letter to the FCA. It is neither a criminal conviction of Staley nor a liability ruling against Barclays for Epstein’s crimes.
The Maxwell account and transfer amounts rest on Reuters’ analysis of DOJ documents, emails and a wealth report. Indexed public records do not allow an independent reconstruction of every movement or the account’s full operation.
Holding an account or making a transfer does not by itself prove an offence. This article does not characterise the funds as criminal and infers no SAR from their existence.
The account attributed to Maxwell does not prove an account in Epstein’s name, Epstein’s control of that account or services supplied directly to Epstein by Barclays.
The US lawmakers’ letter asks questions and repeats some media allegations. It is not a court decision and does not prove its own hypotheses.
The Merritt decisions concern the sufficiency of civil claims. They do not decide liability on the merits. The 28 July 2026 order dismisses the UK claim without leave to amend and leaves the US federal claims pending as of that date.
The source review and the absence of a detailed public response from the lawmakers or Barclays are current to 9 August 2026. Non-publication does not prove the absence of a confidential response, investigation or regulatory work.