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Correspondence

 BARCLAYS HAS CLAIMED CONFIDENTIAL

TREATMENT OF PORTIONS OF THIS LETTER IN

 ACCORDANCE WITH 17 C.F.R. 200.83

 Barclays PLC

One Churchill Place

London E14 5HP

 Michael Seaman

Special Counsel

 Securities and Exchange
Commission

 Washington D.C. 20549

USA

 18 October 2010

 VIA EDGAR

 Dear Mr Seaman,

 Barclays PLC and Barclays Bank PLC

Form 20-F for the Fiscal Year Ended 31 December 2009

 Form 6-K filed 08/05/2010

 File No. 0-10257, 1-09246

This letter responds to the comment letter from the Staff of the Securities and Exchange Commission (the ‘Commission’) dated 8 September
2010 (the ‘Comment Letter’), concerning the Annual Report on Form 20-F for the fiscal year ended 31 December 2009 (the ‘2009 Form 20-F’) of Barclays PLC and Barclays Bank PLC and the Interim Results Announcement
for the six months ended 30 June 2010 (the ‘August Form 6-K’). Barclays PLC, Barclays Bank PLC and their subsidiaries are collectively referred to herein as ‘Barclays’ or the ‘Group’.

To facilitate the Staff’s review, Barclays has included in its responses the captions and numbered comments in bold text and has provided Barclays
responses immediately following each numbered comment.

 In some of the responses, in light of the Staff’s comments, Barclays propose
providing disclosures in our Annual Report on Form 20-F for 2010 (‘2010 Form 20-F’) that may differ from or supplement the corresponding disclosure in the 2009 Form 20-F. Barclays continues to believe its prior filings are in compliance
with applicable disclosure rules and regulations promulgated by International Financial Reporting Standards (‘IFRS’) and the Commission. Accordingly, any changes implemented in future filings should not be taken as an admission that prior
disclosures were deficient or inaccurate.

 In addition, in accordance with what we understand to be the Staff’s policy with respect to
requests for confidential treatment of responses to the Staff’s comment letters, we are submitting two separate letters to the Staff’s comments. Concurrent with the submission to you of this letter, confidential treatment of portions of
this letter is being requested under the Commission’s rules in accordance with 17 C.F.R. § 200.83. Accordingly, a separate version of this response letter containing confidential information of Barclays is being filed by hand and not via
EDGAR. This letter being submitted via EDGAR does not contain confidential information of Barclays and therefore is not submitted on a confidential basis.

 We acknowledge that:

•

 Barclays is responsible for the adequacy and accuracy of the disclosure in the filing;

 1

•

 Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the
filing; and

•

 Barclays may not assert Staff comments as a defence in any proceeding initiated by the Commission or any person under the Federal securities laws of
the United States.

 Our responses to your comments are set out in the appendix to this letter.

 Yours sincerely,

 /s/ C.G. Lucas

 C.G. Lucas

 Group Finance Director

 Cc

David Irving

Sharon Blume

Eric Envall

Pradip Bhaumik

(Securities and Exchange Commission)

George H White

John O’Connor

Elizabeth Davy

(Sullivan & Cromwell LLP)

Philip Rivett

(PricewaterhouseCoopers LLP)

Andrew Ratcliffe

(PricewaterhouseCoopers LLP)

 2

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Michael Seaman

 Securities and Exchange Commission

Appendix 1

 Form 20-F for the fiscal year
ended 31 December 2009

 General

1.
We are aware of press releases by the U.S. Department of Justice and the New York County District Attorney’s Office, dated August 18, 2010, to the effect
that you have agreed to forfeit $298 million for having conducted illegal transactions on behalf of customers from Cuba, Iran, Sudan, and certain other sanctioned countries from the mid-1990s through 2006. We note the disclosure on page 222 of your
Form 20-F, in Note 36 to the financial statements, regarding this matter. We also note from the disclosure on page 117 of your Form 20-F that you operate in Africa and the Middle East, regions generally understood to include Sudan, Syria, and Iran.
As you know, Cuba, Iran, Sudan, and Syria are identified by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls.

Please describe to us the nature and extent of your past, current, and anticipated business activities related to, or contacts with,
Cuba, Iran, Sudan, and Syria, whether through subsidiaries, affiliates, or other direct or indirect arrangements. Your response should describe any business contacts you have had with the governments of the referenced countries or entities
affiliated with, or controlled by, those governments. Identify any state-owned entities that have received financing from, or arranged by, you, and the uses made of the funds received. In addition, discuss the applicability of Section 104 of
the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 to your activities related to Iran.

 Barclays does not have,
and does not anticipate having, a subsidiary, branch, representative office or other physical presence in Iran, Syria, Sudan or Cuba (collectively, the ‘Subject Countries’).

 As set out in more detail in our response to Comment 2, Barclays does not believe that its business activities related to, or contacts with, the Subject Countries are material or that its activities in
the Subject Countries would constitute a material investment risk for our security holders. Furthermore, our activities in the Subject Countries have been further reduced since Barclays introduced, in December 2006, an enhanced Group sanctions
policy (the ‘Sanctions Policy’), which has been subject to further modifications since December 2006 and now applies to all of Barclays operations globally and significantly restricts business and dealings with countries subject to U.S.
sanctions. The Sanctions Policy, which exceeds Barclays legal obligations has been voluntarily adopted. Existing activities relating to these Subject Countries are severely limited by the Sanctions Policy or relate to certain legacy transactions
entered into prior to the implementation of the prohibitions under the Sanctions Policy, such as trade financing agreements that have yet to expire under the terms of those agreements.

 Prior to the introduction of the Sanctions Policy in December 2006, our business activities related to, or contacts with, the Subject Countries primarily comprised the following: financing for
import/export contracts (including guarantees and letters of credit), primarily for U.K. and other European corporate clients doing business in the Subject Countries; correspondent banking services to financial institutions controlled by the
governments of the Subject Countries and private financial institutions located in the Subject Countries; and private banking and wealth management services to clients domiciled or resident in the Subject Countries.

Prior to the Sanctions Policy, we also engaged in the following activities related to the Subject Countries: maintaining deposit accounts for corporate
and retail clients resident or domiciled in the Subject Countries; providing accounts and financing arrangements for customers not resident or located in the Subject Countries but who may have engaged in business with Subject Country counterparties;
providing corporate credit card services to an Iranian government-owned bank; and providing credit card accounts held by residents in the other Subject Countries.

 3

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Michael Seaman

 Securities and Exchange Commission

Appendix 1

 In addition, only with respect to Iran and prior to the introduction of the Sanctions Policy in December
2006, we engaged in the following activities:

•

 Money market transactions with three U.K. subsidiaries of Iranian government-controlled banks – [***CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND
FURNISHED SEPARATELY TO THE COMMISSION];

•

 Participation in syndicated loan transactions, arranged by third-country banks, for Iranian government-owned banks; and

•

 Provision of performance guarantees and structured trade and export finance arrangements for Iranian government-owned banks.

 As noted above, the Sanctions Policy introduced in December 2006 severely limited activities with the Subject Countries.
The Sanctions Policy was further modified in 2008-2009.

 Since the implementation of the Sanctions Policy, subject to very limited exceptions
(such as where we consider that there is a case for permitting a transaction which is already authorised by an OFAC license or lawful legacy business in respect of which Barclays has existing contractual obligations) we prohibit business related to
Iran in all currencies. These exceptions comprise a small number of outstanding legacy trade finance obligations, mortgages, overdrafts, loans, other investments as well as one legacy de minimis commercial relationship in the U.K. with an entity
affiliated with the Iranian government, all outside the scope of U.S. Sanctions.

 We prohibit business activities related to Syria where they
have a U.S. nexus such as U.S. dollar-denominated transactions as well as transactions involving U.S. persons or U.S. origin products and services. Existing activities related to Syria include a small number of outstanding legacy trade finance
obligations, such as overdrafts, loans and other investments, all outside the scope of U.S. Sanctions.

 We severely restrict business
activities relating to the territory of Sudan subject to the U.S. Sanctions and to the government of Sudan subject to extremely limited exceptions such as where we agree to facilitate legally permitted payments required for humanitarian aid or
related to the United Nations’ activity in that area. In addition to this activity related to Sudan, the Group maintains a small number of legacy loans, other investments and wealth management products, all outside the scope of U.S. Sanctions.

 Different jurisdictions within which Barclays operates (e.g., the E.U. and the U.K.) have differing laws relating to Cuba. Barclays has a
policy in place to ensure compliance with its legal obligations in the countries in which it operates and Barclays has a small number of (non-U.S. related) customers who are either Cuban nationals or resident in Cuba. Existing activities related to
Cuba comprise (European) retail and wealth management accounts, mortgages, loans and investment products held by residents and nationals of Cuba, all outside the scope of U.S. Sanctions.

 We do not believe that Section 104 of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 will affect Barclays current or future activities related to Iran because the Group
does not engage in, our Sanctions Policy prohibits engaging in, and we have implemented enhanced screening systems, among other measures, and continue to improve related systems and controls to help prevent engaging in, the activities prohibited by
Section 104.

 4

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Michael Seaman

 Securities and Exchange Commission

Appendix 1

2.
Please discuss the materiality of your business activities and other contacts with Cuba, Iran, Sudan, and Syria, described in response to the foregoing comment, and
whether they constitute a material investment risk for your security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of any revenues, assets, and liabilities associated with each of the
referenced countries for the last three fiscal years and the subsequent period. Also, address materiality in terms of qualitative factors that a reasonable investor would deem important in making an investment decision, including the potential
impact of corporate activities upon a company’s reputation and share value. As you may know, various state and municipal governments, universities, and other investors have proposed or adopted divestment or similar initiatives regarding
investment in companies that do business with U.S.-designated state sponsors of terrorism. Your materiality analysis should address the potential impact of the investor sentiment evidenced by such actions directed toward companies that have
operations associated with Cuba, Iran, Sudan, and Syria. In this regard, please also address the potential impact of the forfeiture and underlying legal matters described in the Department of Justice and New York County District Attorney’s
Office press releases.

 We do not believe that our past, current or anticipated business activities in or other contacts
with the Subject Countries are material in quantitative or qualitative terms and do not believe that such operations or contacts constitute a material investment risk to our security holders for the following reasons:

Quantitative Analysis

 As
discussed in our response to Comment 1, the Group’s contacts with the Subject Countries have been reduced since the introduction of the Sanctions Policy in December 2006, and our activities in those countries are now extremely limited or
negligible, particularly in the context of the Group’s overall business. The tables below set forth the Group’s revenues, assets and liabilities as of and for the year ended 31 December 2009 and as of and for the six months ended
30 June 2010, which are our estimates of amounts attributable to each of the Subject Countries. Relative to the Group’s total revenues, assets and liabilities, these amounts are extremely immaterial. For example, the revenues as a
percentage of total revenues for the six months ended 30 June 2010 for each of the Subject Countries are: less than 0.004% for each of Iran, Syria and Sudan and less than 0.0002% for Cuba. For the purposes of preparing this response, the Group
has gone to considerable effort to retrieve and analyse the information retrievable from the review of its operations. We respectfully advise the Staff that it has proven impracticable to extract all of the comparable figures for years 2007 and 2008
as this would be very time consuming and expensive to collate. However, the Group has no reason to believe that the materiality of the amounts for 2007 and 2008 would be different from the materiality of the amounts in 2009 in the context of the
Group as a whole. The Group requests that the Staff accept the information supplied herein without requiring the Group to go to great additional expense, time and effort in an attempt to provide additional financial information.

As of and for the year ended 31 December 2009, as
applicable
(in millions of U.S. $)1

Revenues

Assets

Liabilities

 Iran

<$2

<$20

<$70

1
 Although the figures presented above are stated in U.S. dollars for the sake of consistency, that does not mean that the underlying business activities
are conducted or involve transactions denominated in U.S. dollars.

 5

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Michael Seaman

 Securities and Exchange Commission

Appendix 1

 Syria

<$2

<$40

<$260

 Sudan

<$1

<$5

<$30

 Cuba

<$0.05

<$2

<$2

As of and for the six months ended 30 June 2010,
as applicable
(in millions of U.S. $)1

Revenues

Assets

Liabilities

 Iran

<$1

<$20

<$85

 Syria

<$1

<$30

<$285

 Sudan

<$1

<$5

<$35

 Cuba

<$0.05

<$2

<$2

 These figures above represent
Barclays exposure to the Subject Countries through either direct or indirect customer relationships across our Retail, Corporate, and Wealth Management businesses (there is