The Wolfsberg Group has published updated Anti-Bribery and Corruption [“ABC”] Compliance Programme Guidance, helping to promote a culture of ethical business practices and compliance with ABC legal and regulatory requirements.
Developed alongside the Basel Institute on Governance and with input from Transparency International, the Guidance highlights the importance of taking a risk-based approach when developing and implementing ABC programmes.
The Group provides guidance on measures which firms may wish to adopt, including:
- Elements of an effective ABC programme;
- Firm-wide policy;
- Third-Party providers;
- Principal investments & controlled fund acquisitions / joint ventures;
- Anything of value;
- Risk assessment;
- Training and awareness;
- Monitoring and testing for compliance with controls; and
- Customer-related corruption risks.
The guidance also provides examples of corruption red flags in the document annex.
Firms should read the updated guidance document and take appropriate actions, as required.