By settling with the SEC for $6.3 million, Barclays PLC recently closed a chapter on its less-than-ideal hiring practices in the Asia Pacific region where friends and relatives of clients and government officials were given internships and jobs to win business. The SEC alleged that, even though Barclays had anti-corruption policies prohibiting employment offers from being made in exchange for business, about 117 friends and family of business connections were onboarded with the expectation that their presence at Barclays would boost its own business and open doors to getting even more. For the regulated community, this case, and the string of similar cases before it, that means that it might be time for corporate compliance and human resources functions to work together a bit better. See our two-part series on managing corruption risk when hiring and training foreign officials and their relatives overseas: “Risks and Challenges
” (Jul. 27, 2016) and “Practical Compliance Guidance”
(Aug. 10, 2016).