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Investigators Detail Where Compliance Officers Fell Short in Barclays' Relationship Hiring

Sue Reisinger
Corporate Counsel
September 30, 2019

Arthur Middlemiss spoke to Corporate Counsel regarding the September 27, 2019 consent order entered by the U.S. Securities and Exchange Commission detailing corruption offenses by Barclays PLC. 

Arthur Middlemiss, a partner at Lewis Baach Kaufmann Middlemiss in New York, focuses his practice on financial crimes and compliance. Middlemiss told Corporate Counsel, “The bank seems to have gotten halfway home. It recognized the risk and implemented policies, but failed to implement them.”

He said the settlement teaches in-house counsel two key lessons: First, “execute an adequate risk assessment and adjust compliance mechanisms; [then] make sure those mechanisms are working.”

If employees violate the policy, Middlemiss said, there needs to be an immediate and commensurate reaction. That could mean retraining, repercussions with respect to performance review and compensation, or firing, depending on the nature of the foul.

“But the case again proves that good governance requires policy execution,” Middlemiss added, “and policy execution requires adequate resources dedicated to training and audit.”

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