Anti-Bribery and Corruption (ABC) requirements and Anti-Money Laundering (AML) regulations go hand in hand. While AML frameworks are designed to prevent criminals from disguising illicit funds as legitimate, ABC rules focus on preventing financial misconduct that often enables money laundering in the first place.

As a compliance manager, your job is to ensure that your company’s policies are up to date and adhere to these requirements, which not only protects your business but also builds a culture of integrity.

One of the main components of an effective ABC programme is clear anti-bribery and corruption policies. These policies should be accessible to all employees and contractors and should outline prohibited conduct, such as offering or receiving bribes in exchange for business favours. This also includes any form of conflict of interest, where individuals may use their position to benefit personally or commercially.

Training and awareness programmes are vital for reinforcing these policies and ensuring that everyone in the organisation understands what constitutes bribery and corruption, how to identify red flags, and how to report suspicious activities.

For compliance professionals, implementing a comprehensive due diligence process is an important part of managing ABC risks. You need to verify the backgrounds of business partners, suppliers, and clients, ensuring they adhere to ethical standards. This due diligence process should be part of your broader risk management strategy, with increased scrutiny of high-risk jurisdictions, sectors, or individuals who may be more prone to engaging in corrupt practices.

Monitoring and auditing are also vital in detecting potential bribery or corruption. Keeping a close watch on financial transactions and changes to customer risk profiles, especially those involving third parties, can provide early warning signs of possible illicit activities. As an AML compliance manager, you should ensure your team has the right tools to continuously track transactions and risk profiles for any suspicious patterns or activities that may indicate bribery or corruption. For example, large or unusual payments to or from foreign countries, especially where there are no clear business justifications, can be a red flag. Additionally, random or irregular gifts and entertainment exchanges should be monitored, as they could point to attempts to influence decisions inappropriately.

The Bribery Act also introduced the concept of strict liability for companies, meaning that a company can be held liable if an employee or associate bribes someone on its behalf, even if the company didn’t know about it. This is where having an effective ABC compliance programme really comes into play. It’s not enough to simply have policies in place – you must actively work to prevent bribery and corruption by creating a culture of transparency, encouraging employees to report concerns without fear of retaliation, and auditing financial activities regularly to catch potential issues before they become a problem.