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An effective ABC compliance program 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. 

Home > Financial Crime Compliance > Bribery & Corruption


Bribery is a specific offence which concerns the practice of offering something, usually money, to gain an illicit advantage and corruption is an abuse of a position of trust in order to gain an undue advantage. Overall, bribery and corruption reduces efficiency and increases inequality. Estimates show that the cost of corruption equals more than 5% of global GDP or about US$ 2.6 trillion, with over US$1 trillion paid in bribes each year.  Engaging in corrupt practices creates a very unfavourable business environment by encouraging unfair advantage and anti-competitive practices.  As well as allowing organised crime to flourish, corruption is one of the primary obstacles to the economic development of a country; it undermines the rule of law, weakens trust in public institutions and challenges democratic principles. 


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 anti-bribery and corruption (ABC) programs.  These programs 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 order to determine the adequacy of existing systems and controls and whether they meet the relevant ABC standards, we perform some or all of the following for our clients:

  • Risk Assessment.

  • Compliance Reviews of procedures, systems and controls against current ABC policy.

  • Control Framework reviews of the business to determine the scope and risk profile of the business in question, internal and external relationships, existing controls, etc.

  • Look-Back Reviews to identify root causes in relation to past incidents and near misses. 

  • Payment Analytics and Forensic Investigations of suspected bribery and corruption activity.

  • Staff Training & Awareness of UK and international bribery legislation.

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