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CORRESP
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CORRESP

 Barclays PLC

One Churchill Place

 London E14
5HP

 Stephanie J. Ciboroski

 Senior
Assistant Chief Accountant

 Securities and Exchange Commission

Washington DC 20549

 USA

31 October 2013

 Dear Ms Ciboroski,

Barclays PLC and Barclays Bank PLC

 Form 20-F for the
fiscal year ended December 31, 2012

 Filed 13 March 2013

Form 6-K

 Filed 16 April 2013

Files No. 001-09246 and 001-10257

 This letter
responds to your letter (the “Comment Letter”), dated 21 June 2013, concerning the Annual Report on Form 20-F for the fiscal year ended 31 December 2012 (the “2012 Form 20-F”) of Barclays PLC and Barclays Bank
PLC (collectively, “Barclays”) and the Report on Form 6-K relating to the Restatement Document (the “April Form 6-K”). By our letter dated 26 July 2013, we responded to comments 3 through 14 of the Comment Letter and we are
in this letter now responding to comments 1 and 2. As we discussed with the Staff and confirmed in our letter of 29 July 2013, our responses to comments 1 and 2 were to be provided by 31 October 2013.

Our responses to comments 1 and 2 are set out in Appendix 1 to this letter. To facilitate the Staff’s review, Barclays has included in its response the
numbered comments as raised in the Comment Letter and provided responses immediately following each numbered comment.

 Yours sincerely,

/s/ Tushar Morzaria

 Tushar Morzaria

Group Finance Director

Cc
Rebekah Lindsay

 (Securities and Exchange Commission)

John O’Connor

 Eric J. Kadel
Jr.

 (Sullivan & Cromwell LLP)

 Stephanie J Ciboroski

Securities and Exchange Commission

 Appendix 1

1.
In your letter to us dated October 18, 2010, you discussed your contacts with Cuba, Sudan, and Syria. It appears from the disclosure on page 322 that you continue to maintain legacy guarantees related to Syria.
In addition, publicly-available information indicates that you have a correspondent banking relationship with Byblos Bank, which operates in Sudan and Syria. As you know, Cuba, Sudan, and Syria are designated as state sponsors of terrorism by the
U.S. Department of State, and are subject to U.S. economic sanctions and export controls. Your Form 20-F does not include disclosure regarding contacts with Cuba or Sudan, or disclosure beyond the limited information on page 322 regarding contacts
with Syria. Please describe to us the nature and extent of your past, current, and anticipated contacts with Cuba, Sudan, and/or Syria, whether through direct or indirect arrangements, since the referenced letter. Your response should describe any
funds, services, or support you have provided or intend to provide into Cuba, Sudan, and/or Syria, directly or indirectly, and any agreements, arrangements, or other contacts you have had or intend to have with the governments of those countries or
entities they control.

 Our activities in Syria, Sudan and Cuba (collectively, the ‘Subject Countries’) are
substantially limited since December 2006, when Barclays introduced an enhanced Group Sanctions Policy (the ‘Sanctions Policy’), which applies to all of Barclays operations globally. The Sanctions Policy significantly restricts business
and dealings with countries subject to U.S. sanctions, including the Subject Countries.

 Barclays does not have, and does not anticipate
having, a subsidiary, branch, representative office or other physical presence in any of the Subject Countries.

 Syria

With regard to Syria, Barclays tightened the restrictions in its Sanctions Policy on a number of occasions in response to the continued
strengthening of Syrian sanctions during 2011 and 2012. During the period leading up to September 2012, Barclays Sanctions Policy in relation to Syria reflected its legal obligations, restricting among others business activity which involved a
sanctioned party, a US nexus, a Syrian financial institution, or activity relating to the oil and gas sectors. In September 2012 due to further consideration of its risk tolerance with regard to Syria, Barclays restricted business activity relating
to Syria in all circumstances, requiring activity to be escalated to the central Sanctions team for consideration on a case by case basis if the business wishes to proceed with the activity and only where the activity is legally permissible. As a
result of this change in risk tolerance, from September 2012 Barclays exited many of its customer relationships with Syrian residents and put in place dispensations from the Sanctions Policy to allow for measured exits with appropriate notice given
to affected customers in accordance with our legal obligations. Where it has not been possible to exit particular customers for some time due to local legal or regulatory constraints, for example, customers with mortgages, exceptions against the
Sanctions Policy have been granted and appropriate additional controls put in place. These customer relationships were legally permissible but were being exited due to Barclays’ risk tolerance. In light of these changes, our existing activities
related to Syria are limited and include (in addition to the activities described in our Annual Report on Form 20-F) a relatively small number of legacy obligations, all of which we believe are outside the
scope of the prohibitions under applicable U.S. sanctions.

 2

 Stephanie J Ciboroski

Securities and Exchange Commission

 Appendix 1

 Sudan

We have severely restricted business activities relating to the territory of Sudan which is the target of U.S. sanctions, and to the government
of Sudan. In 2012, Sudanese sanctions distinguished the regional government of Southern Sudan from the Government of the Republic of Sudan (North Sudan). Barclays Sanctions Policy in relation to Sudan was amended to reflect the change in legal
obligations, continuing to restrict among others business activity which involved a sanctioned party, and military goods, technology, and services. In addition to these restrictions, business activity involving a US nexus and North Sudan, or
the Government of North Sudan remained restricted in all circumstances, requiring activity to be escalated to the central Sanctions team for consideration on a case by case basis if the business wishes to proceed with that activity and only
where the activity is legally permissible. The applicable restrictions are subject to limited exceptions that must be agreed by the central Sanctions team upon escalation, such as facilitation of legally permitted payments required for humanitarian
aid or related to the United Nations’ activity in Sudan and the surrounding areas. In addition, Barclays maintains a small number of legacy loans, other investments and wealth management products, all of which we believe are outside the scope
of the prohibitions under applicable U.S. sanctions.

 Cuba

Barclays Sanctions Policy in relation to Cuba reflects its legal obligations, restricting among others business activity relating to Cuba which
involves a sanctioned party or a US nexus, as well as Cuban nationals wherever resident if there is a US nexus to the activity. Where business activity relating to Cuba is restricted by the Sanctions Policy, Barclays requires activity to
be escalated to the central Sanctions team for consideration on a case by case basis if the business wishes to proceed with that activity and only where the activity is legally permissible.

Certain jurisdictions in which Barclays operates (e.g., the E.U. and the U.K.) have laws relating to Cuba that differ from those of the United
States. Barclays Sanctions Policy is 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. customers who are either Cuban nationals or resident in Cuba. Existing
activities related to Cuba include (European) retail and wealth management accounts, mortgages, loans and investment products held by residents and nationals of Cuba, all of which we believe are outside the scope of the prohibitions under applicable
U.S. sanctions.

 Correspondent Banking Relationships

We prohibit correspondent banking relationships with institutions in the Subject Countries. Our correspondent banking relationships are subject
to, and are in compliance with, our Sanctions Policy. Some of our correspondent banks, such as Byblos Bank in Lebanon, have operations in Syria and Sudan. However, we do not have direct correspondent banking relationships with Byblos Bank, nor with
any other bank in Syria or Sudan.

 In addition, Barclays reviewed its global list of its correspondent banking relationships to identify
banks with apparent direct operations in any of the Subject Countries. The review identified that, while Barclays does not have correspondent banking relationships with banks located in any of the Subject Countries, some of Barclays’
correspondent banks themselves have a presence within one or more of the Subject Countries.

 Barclays has systems, controls and procedures
to identify, escalate and review correspondent banking relationships with links to sanctioned countries, including the Subject Countries. Barclays screening systems are configured to detect transactions, including those received through Barclays
correspondents, involving the Subject Countries.

 3

 Stephanie J Ciboroski

Securities and Exchange Commission

 Appendix 1

 Barclays applies a risk-based approach on its correspondent banking relationships. It
performs due diligence on all of its correspondents, and reviews, among others, the correspondent banks’ sanctions programmes, including sanctions screening systems, the sanctions lists used in screening, and relationships with banks in
sanctioned countries. Barclays requests from its higher risk correspondent banks, information about the correspondents’ SWIFT keys exchanged through their relationship management application (RMA), their use of Nostro and Vostro accounts, and
informs them of the details of the sanctioned countries and parties that Barclays does not wish to deal with directly or indirectly. Our correspondent banking relationships are subject to periodic risk review and monitoring.

As set out in more detail in our response to Comment 2, Barclays does not believe that its business activities that relate to, or its contacts
with, the Subject Countries, as described above, are material nor that its activities in the Subject Countries would constitute a material investment risk for our security holders.

2.
Please discuss for us the materiality of the contacts with Cuba, Sudan, and/or Syria you describe in response to the foregoing comment, and whether those contacts constitute a material investment risk for your
security holders. You should address materiality in quantitative terms, including the approximate dollar amounts of any associated revenues, assets, and liabilities for the last three fiscal years and the subsequent interim 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 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, Sudan, or Syria.

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, Barclays contacts with the Subject Countries are restricted, in accordance with the Sanctions Policy, and the qualitative and quantitative value of our limited activities in those countries is negligible in
the context of Barclays overall business. The tables below set forth Barclays revenues, assets and liabilities as of and for the year ended 31 December 2012, which are our estimates of amounts attributable to each of the Subject Countries.

Relative to Barclays global total revenues, assets and liabilities as published in the restated financial statement for the year ended
31 December 2012, these amounts are considered immaterial. For example, revenues for each of the Subject Countries as a percentage of total revenues were: less than 0.003% for Syria, less than 0.002% for Sudan and less than 0.005% for Cuba. In
addition, assets for each of the Subject Countries as a percentage of total assets were: less than 0.0009% for Syria, less than 0.00004% for Sudan, and less than 0.003% for Cuba. Liabilities as a percentage of total liabilities were: less than
0.003% for Syria, and less than 0.002% each for Sudan and Cuba.

 4

 Stephanie J Ciboroski

Securities and Exchange Commission

 Appendix 1

 For the purposes of preparing this response, Barclays has gone to considerable effort to
retrieve and analyse the information available. We respectfully advise the Staff that it has proven impracticable to extract all of the comparable figures for years 2010 and 2011, and for the interim period six months ended 30 June 2013, as, in
light of the extremely limited nature and immateriality of this to the business as a whole, we believe this would be very time consuming and expensive to collate and provide no additional information that would be of use to investors. However,
Barclays has no reason to believe that the materiality of the amounts for 2010 and 2011, or for the interim period ended 30 June 2013 would be different in any significant respect from the materiality of the amounts in 2012 in the context of
Barclays as a whole. Barclays respectfully requests that the Staff accept the information supplied herein without requiring Barclays 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 2012, as applicable

(in millions of U.S. $)1

Revenues

Assets

Liabilities

 Syria

<$0.7

<$14

<$42

 Sudan

<$0.5

<$0.6

<$26

 Cuba

<$1.1

<$39

<$27

 The figures presented 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 no exposure within Barclays Investment Bank).

The information in this letter shows changes in customer activity relative to the information reported in our October 2010 letter relating to
the Subject Countries, although still at immaterial levels. The changes can be attributed to the following reasons. Firstly, Barclays has further strengthened its SEC reporting processes and procedures. Secondly, Barclays has invested
a significant amount of resources to enhance its Sanctions Policy, screening systems, and controls in activity relating to sanctioned countries. These enhancements have resulted in better identification and reporting of activity involving
sanctioned countries. The process of collecting information for this letter has relied on the information provided by these enhanced systems and controls. Thirdly, these enhancements also enable Barclays to better enforce its Sanctions
Policy and risk tolerance, and specifically, severely restricting activity relating to the Subject Countries to meet its sanctions obligations, while allowing legally permissible business activity. Fourthly, values are subject to fluctuations of
fair values of assets and liabilities as at 31 December 2012.

1
Although the figures presented above are stated in U.S. dollars for the sake of consis