Compliance and robust corporate governance

Compliance with legal and regulatory requirements is vital. The maintenance and enhancement of a robust control environment is a key priority for Barclays, and we are committed to delivering this to the highest standards. We are allocating substantial resources, including investing in IT and people-driven solutions, to enhance our systems and processes.

Financial institutions are at the forefront of the fight against criminals who attempt to defraud, launder money or finance terrorism and against weapons proliferation. We have a legal, regulatory, moral and social responsibility to restrict the access of criminals to the financial services market.

Anti-money laundering

Money laundering is the process whereby the origins of the proceeds of crime are disguised to allow criminals to benefit, and the financial system is often used to this end.

The Barclays Anti-Money Laundering (AML) Policy is designed to ensure that all parts of our organisation, across all jurisdictions of operation, comply with the requirements and obligations set out in relevant legislation, rules and industry guidance for the financial services sector. This includes assisting in the prevention of organised crime and terrorism. The Policy also requires identifying whether customers, or related parties, are politically exposed.

Barclays is a founder member of the Wolfsberg Group, which aims to develop financial services industry standards relating to 'know your customer', AML and counterterrorist financing policies.

Sanctions

Sanctions are official restrictions on activity with targeted countries, individuals, entities and industries. Barclays is committed to complying with financial sanctions and export controls in order to comply with the law, help prevent weapons proliferation, organised crime and terrorism and protect the reputation of Barclays. We have a duty not to deal with individuals who are subject to financial sanctions.

Barclays Sanctions Policy sets out how we will adhere to sanctions law and places restrictions on:

• The individuals and entities with whom we can establish or maintain a business relationship
• All business activities that Barclays undertakes.

Failure to comply with AML and sanctions requirements can expose Barclays to civil and criminal liability, fines, loss of reputation, public reprimand, limitation on business, and other serious consequences. For our colleagues, failure to comply with AML and sanctions can result in personal liability such as fines and imprisonment. Colleagues who fail to comply with the Barclays AML Policy and the Sanctions Policy may be subject to disciplinary action up to and including dismissal.

Bribery and corruption prevention 

Across the Barclays Group, we have a zero tolerance approach to bribery and corruption, and compliance with our Bribery and Corruption policy is mandatory for all employees, regardless of their location.

Failure to comply with the Policy may also result in severe disciplinary action, up to and including dismissal. 

Data protection 

We take our data protection responsibilities seriously. As part of a Group-wide privacy programme, we have established a network dedicated to privacy and data protection across Barclays. We have also enhanced our incident management framework to ensure that we identify any issues that should arise when they occur and mitigate them quickly. 

Fraud 

Barclays operates a fraud risk control framework reflecting the importance given to managing the risks posed by fraud. The Group Fraud Management Committee meets monthly to review fraud levels and the effectiveness of our controls in preventing losses. This helps in the identification of emerging fraud risks and trends, so that timely action may be taken to refine our controls to protect Barclays and our customers.

The threat posed by fraud continually evolves as criminals seek new ways of attack; we therefore remain constantly aware of this threat and invest appropriately to enhance our fraud prevention capability on an ongoing basis.

The protection of our customers from fraud is a key priority and we therefore carefully manage the balance between the accessibility of our products and services against this, while ensuring our legal and regulatory obligations are complied with in full.