The filed complaint alleges that defendants made false statements and/or concealed that: (1) contrary to his false public assertions, Barclays' CEO, Jes Staley, had a close relationship with Jeffrey Epstein; (2) Staley was reportedly aware of Jeffrey Epstein’s criminal activities and may have even sexually assaulted a victim who had previously been trafficked by Jeffrey Epstein; (3) Staley’s close, personal relationship with Jeffrey Epstein and potential criminal activity could, if discovered, bring reputational, legal, and financial harm to Barclays; (4) as a result, Barclays response to the British Financial Conduct Authority'("FCA") inquiry regarding Staley’s relationship with Epstein was materially false; (5) Barclays, having become aware of information contradicting its response to the FCA’s inquiry, then failed to update the response so that it would be accurate, or otherwise take any meaningful action; and (6) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.