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Anti-Bribery & Corruption
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. 


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) 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.

How can we help?

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 assessments.

  • 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 and awareness of UK and international bribery legislation.

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