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Bribery and corruption: is your organisation ready to prevent it?

While KYC and AML have been front of mind when it comes to compliance and the fight against fraud, anti-bribery and corruption compliance hasn’t been in the spotlight as much lately. However, that doesn’t mean you shouldn’t be paying close attention to it.

Why is it important?

Preventing bribery and corruption is a high priority for governments across the globe. Penalties have increased across different jurisdictions and efforts have been made to create international standards. Acknowledging that governments alone can’t fight this threat, there has been an increased focus on self-regulation and corporate compliance.

Both in the USA and UK, companies involved in bribery and corruption could face fines and criminal and civil penalties that include jail time for failure to prevent such acts. For example, the UK Bribery Act goes beyond bribery to public companies, including the private sector as well. The United State’s Foreign Corrupt Practices Act (FCPA) can be seen as a companion to the UK legislation and sets a global standard for corruption, as it was amended to include domestic and foreign companies. You can find more information on specific jurisdictions here, but the bottom line is: if companies don’t have an effective anti-bribery and anti-corruption compliance programme in place, they can face dire consequences.

How can an organisation be prepared to fight this battle?

With the complex landscape of a fast-paced, globalised world, that involves doing business across different geographies and working with multiple third-parties across their supply chain, companies need to make sure they are operating safely and doing all they can to prevent bribery and corruption from happening under their watch. Here are 5 tips to address the challenge:

  1. Establish a robust third-party risk management framework. Understand who you’re doing business with and how they operate, as this can often be the weakest link in your efforts towards compliance. You can find detailed information here on managing third parties. 

  2. Have a full grasp of international laws and guidelines to make sure you’re operating safely across different jurisdictions. OECD, UNODC, and World Bank have put together a handy guide on Anti-Corruption and Ethics and Compliance for Business that can help you get a head start.

  3. Stay on top of changes in regulations and adapt at speed. It starts with having the right technology and processes in place. Make sure you review your current processes, identify areas of risk to the business and look for the best technology solutions to support your needs. Relying solely on manual processes just won’t cut it anymore, as they are prone to human error and too slow to cope with the speed of the market. You need to be able to automate key, time-consuming tasks, such as policy management. Companies like Currencycloud decided to adopt fit-for-purpose solutions to facilitate ongoing compliance with a rapidly-changing global regulatory landscape, enable smarter collaboration across their expanding global footprint, and automate previously manual, time-consuming document management tasks.

  4. Keep staff in the know. Disseminate the relevant, up-to-date policies and procedures they need to follow to perform their jobs safely and prevent foul play. Organisations such as Barclays have invested in policy distribution platforms to make sure compliance updates reach their employees across the globe.

  5. Demonstrate strong governance to regulators and key stakeholders. Proving you’re doing all you can to prevent corruption and bribery is as important as doing so. Make sure your actions are documented, that you have a full audit trail of all your policies and that you can track and show staff adherence through attestation. Best-in-class policy management solutions should equip you to achieve this goal. If you’re currently using software that is not fit for purpose or legacy technology, you might want to explore other options.

Getting buy-in from the company

As it is often the case with non-revenue-generating functions, companies can relegate investment in compliance technology and cut programme resources short. It is easy to lose sight of all the implications of the lack of investment. Therefore, in order to get the green light for a key project, compliance executives need to be able to demonstrate the reasons behind it, the possible consequences of doing nothing and what the investment will bring to the table.


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