On 17 April 2023, the Wolfsberg Group published its updated 2023 Anti-Bribery and Corruption (ABC) Compliance Programme Guidance, which is designed to provide guidance to the Financial Service Industry on how to develop, implement and maintain an effective ABC Program.
The 2023 Guidance Note updates the 2017 version, and its overall objective is to promote a culture of ethical business practices and compliance with ABC legal and regulatory requirements.
The key differentiator of the Wolfsberg Group's Anti-bribery and Corruption compliance program is its risk-based approach in developing and implementing Anti Bribery and Corruption Compliance Programme. The Guidance addresses following key elements of an Anti Bribery and Corruption Compliance Programme:
- Commitment from the senior management
- Identify rapidly evolving Anti Bribery and Corruption risks and initiate requisite ABC risks mitigation
- Clearly define responsibilities with a proportionate framework
- Employee and third-party training on Anti Bribery and Corruption risks, standards and regulations
- Communicate stance on disciplinary action
- Perform testing of Control environment and establish remediation procedures
The updated Guidance provides for several changes incorporating learning from enforcement since 2017, with expansion to scope of bribery and corruption, red flags sections, employees’ accountability, among others.
To know more about the how it is imperative for financial institutions to tailor their compliance efforts in congruence with international efforts to combat bribery and Corruption, download our point of view document now.
