Bribery & corruption

An effective anti-bribery & corruption (ABC) compliance framework needs to be risk based to ensure that it is properly designed to implement strategies and allocate resources to mitigate the specific and most substantial risks of corruption and bribery facing the business.

The Bribery Act 2010 represents arguably the toughest legal regime against bribery anywhere in the world. Unlike the US Foreign Corrupt Practices Act of 1977 (as amended), the UK requirements cover both domestic and foreign bribery acts.

In order to evidence compliance with the Bribery Act, financial institutions must implement effective ABC programmes. These programmes should include a code of conduct and policies regarding gifts, training, political and charitable contributions, and delegation of authority, as well as accounting policies regarding the proper recording of transactions.

Financial institution must pay specific attention to the risks derived from the global nature of their operations, the degree of business performed on behalf of government entities, the physical location of their banking outlets and the international regulatory environment in which it operates.

In the UK, failing to prevent bribery and corruption is itself an offence. Having an inadequate or ineffective ABC programme can lead to enforcement action, even if there are no specific cases of bribery or corruption present.

People's indifference is the best breeding ground for corruption to grow.

Delia Ferreira Rubio

Transparency International

OpusDatum is here to assist you in your ongoing efforts to mitigate and manage the risks and impacts of bribery and corruption. We can help you assess your current risk exposure and provide support in designing and implementing effective, proportionate, and sustainable controls. Our services include:

Design and implement comprehensive ABC programme including frameworks, policies and standards.
Dedicated ABC risk assessments.
Independent reviews of procedures, systems and controls against current ABC policies and standards.
Enhance and uplift current ABC policies, standards, procedures and controls.
Benchmark ABC controls against best practice.
Look-back reviews to identify root causes in relation to past ABC incidents and near misses.
Payment analytics and forensic investigations of suspected ABC activity.
Staff training and awareness of UK and international bribery legislation.