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Anti-Bribery & Corruption: Managing Emerging Risks

Learn the adequate and effective management of emerging risks with Anti-Bribery and Corruption Training

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A one-day course

Session 1: Global Developments

Several recent developments in AB&C have significant implications for Compliance departments, the management of risk, and the future of their organisations. This anti-bribery and corruption training course covers:

  • Increase in Global Corruption Risks
  • Expanding Regulation & Harsher Penalties
  • US Regulatory Developments:
    • NDAA and the Anti-Money Laundering Act of 2020 (“AMLA”)
    • Biden Administration United States Strategy on Countering Corruption
  • Multijurisdictional Action
  • Increased Compliance Self-Regulation
  • Extending Use of DPA & Other Settlement Options
  • Increased Recognition for Whistleblowers
  • Supply Chains
  • Sanctions & Human Rights
  • China’s Belt & Road Initiative
  • Increased Use of Offshore Entities
  • EU Whistleblowing Directive
  • Ethics
  • This anti-bribery course includes the following case studies:
    • McKinsey and the Opioid Crisis
    • Airbus Corruption Inquiry

Session 2: Developments in Benchmarking

Session 2 of anti-bribery and corruption training provides an overview of some of the best practices adopted.

  • Culture as the Basis for Anti-corruption Compliance Effectiveness
  • Integration of ESG
  • Increased Social Media Checks
  • Challenges in Enhanced Due Diligence
  • Third-Party Risk Management
  • The Role of Automation
  • Blockchain & Cryptocurrencies
  • Case Study: IMF: Crypto, Corruption & Capital Controls

Session 3: OECD 2021 Recommendation on Foreign Bribery

The “Recommendations For Further Combating Bribery of Foreign Public Officials In International Business Transactions”, reinforce some of the earlier recommendations with increased emphasis, while adding new ones. Covered in this anti-bribery and corruption course section:

  • The Recommendations:
    • Greater Proactivity by Government in Investigations & Enforcement
    • Multijurisdictional Cases
    • Data Protection
    • Non-Trial Resolutions
    • Accounting Requirements & External Audits
    • Internal Controls, Ethics & Compliance
    • SOEs and SMEs
    • The Demand Side
    • Solicitation Payments
  • Good Practice Guidance For Companies:
    • Risk-Based Assessments
    • Monitoring of Risks
    • Reassessment of Risks
    • Management Support
    • Corporate Policies
    • Allocation of Compliance Resources
  • Related Recommendations:
    • Export Credits
    • Tax Measures
    • Managing the Risks of Corruption
  • Case Study: Deutsche Bank AG FCPA Resolution

Session 4: AB&C Programme Framework

The Anti Bribery & Corruption Programme Framework is based on Transparency International’s “Diagnosing Bribery Risk: Guidance for the conduct of effective bribery risk assessment”.

  • Top Level:
    • Mission, Strategy, Objectives
    • Management Commitment to AB&C
  • Anti-Bribery and Corruption Risk Assessment
  • Planning
  • Identification
  • Evaluation
  • Plan of Action:
    • Control Mapping
    • Gap Analysis
    • Remediation
  • Follow-up, Monitoring and Enforcement
  • Reporting
  • Anti-bribery and corruption training includes; Case Study: Credit Suisse & Mozambique

Session 5: Good Practice Guidelines on Conducting Third-Party Due Diligence

A framework for conducting third-party and Intermediary Due Diligence based on OECD guidelines for major organisations.

  • What the Law Says:
    • US Foreign Corrupt Practices Act (FCPA)
    • UK Bribery Act
  • Objective Conclusion of Third-Party Due Diligence
  • Risk-Based Due Diligence:
    • Objectives Setting
    • Risk Tolerance
    • Risk Response
  • Scope of Third Parties:
    • Defining Third Parties
    • Level of Due Diligence
    • Initial Screening
  • Third-Party Risk Assessment:
    • Key Risk Indicators
    • Process
  • Anti-bribery course delegates investigate the following case study: Och-Ziff Capital Management Bribery Scandal

Session 6: Conducting Risk-Based Third-Party Due Diligence

A practical approach to conducting due diligence on third parties and intermediaries. Session 6 of anti-bribery and corruption training covers:

  • Data Collection Approach:
    • Media Searches
    • Internal Questionnaire
    • External Questionnaire
  • Data Collection Process:
    • Organisation & Affiliations
    • Necessity & Retention
    • Expertise
    • Compensation, Fees, & Method of Payment
    • Integrity
  • Data Verification & Validation
  • Evaluation of Results, Red Flags
  • Approval Process
  • Post-Approval Risk Mitigation
  • Implementing the Due Diligence Process:
    • Starting at the Top
    • Training
    • Monitoring (Employees & Third Parties)
    • Escalation & Support
    • Disciplinary Action for Non-Compliance
  • Case Study: Goldman Sachs in Malaysia

Session 7: Complex Financial Crimes Involving AB&C

Bribery and Corruption are rarely standalone crimes with money laundering, fraud and tax evasion often in attendance. However, we can also see that there are an increasing number of sanctions regimes that specifically target acts of bribery and corruption.

  • UNODC corruption in specific areas:
    • Sports
    • Wildlife
    • Human Rights
  • Sanctions and Human Rights:
    • The Magnitsky Act
    • The Global Magnitsky Act
    • UK Global Human Rights Sanctions Regulations
    • UK Global Anti-Corruption Sanctions Regulations
    • EU Global Human Rights Sanctions Regime
    • Executive Order 14024
    • DOJ Kleptocrat Taskforce
  • Money laundering:
    • Trade & Illicit Financial Flows
  • Tax evasion:
    • Linked to Fraud, Money Laundering and Bribery & Corruption
    • Trade & Illicit Financial Flows
  • Case Study: The Wagner Group & Sudan Gold
  • Anti-bribery course case Study: Bain Capital Management in South Africa

Session 8: Reputational Risk Impacts

There was a time when the reputational risks of illicit actions could not be readily determined or assessed. Now those risks are increasingly crystallizing in ways that were not previously apparent. Session 8 of our anti-bribery and corruption training course covers:

  • Societal trends
  • Impact of social media
  • Shareholder activism
  • Reputational Risk Management:
    • Legal
    • Communications & PR
    • Anti-Bribery Compliance
  • Case Study: GAM Asset Management
  • Case Study: Petrobras Bribery Scandal
  • Case Study: Bell Pottinger South Africa

As a Chartered Certified Accountant holding an MBA from Cass Business School, our anti-bribery course leader has hands-on experience. With over 20 years dedicated to internal audit, product control, corruption risk management and SOX, our specialist has worked for major global banks in London. In addition, he spent several years at a major bank as a business manager for global markets.

Over the last six years, our expert has led training sessions for several banks and financial institutions on financial crime risk. Delivering these in the UK and to more than 35 countries across the globe, you’re in knowledgable hands with anti-bribery and corruption training at Redcliffe.

Anti-bribery and corruption course delegates develop a greater appreciation and understanding of:
  • Emerging trends impacting Anti-Bribery & Corruption Compliance Programmes.
  • Latest developments in the benchmarking of best practices in AB&C Compliance.
  • Changes in the AB&C legal and regulatory landscape and how they might be approached.
  • Elements of an adequate and effective AB&C Risk Management Framework.
  • Good practices in intermediary and third-party due diligence.
  • The numerous ways in which anti-bribery & corruption interact with other financial crime risks, and the ever-increasing nexus with human rights and sanctions regimes.
  • The importance of having an adequate AB&C reputational risk management framework.

  • Redcliffe’s anti-bribery and corruption training provides a systematic and comprehensive analysis of the many current challenges posed by risks. This includes the interaction with other financial crime risks.
  • Our course covers anti-bribery & corruption benchmark practices, risk-sensitive frameworks, third-party due diligence and international regulatory guidelines.
  • Sessions are practical and highly interactive and participants delve into several highly relevant case studies, exercises and discussion points surrounding anti-bribery regulations.
  • This course has been designed by and is delivered by a professional trainer with extensive experience in banking and financial services. He delivers trading risk management and audit and financial crime training across major global business and product lines.

Anti-bribery and corruption training is suitable for:
  • AB&C risk professionals in general.
  • Managers and risk professionals wishing to establish an AB&C risk management and control framework within their organisation.
  • Anyone wishing to benchmark their AB&C risk management framework and controls against current trends and best practices.
  • Senior managers in banks, institutions and organisations wishing to better understand the risks which might impact their operating environment and how they might be managed.
  • This anti-bribery course is also recommended for risk professionals who need to improve their AB&C knowledge with anti-corruption compliance best practices.

Redcliffe Training has designed this anti-bribery and corruption course to ensure AB&C risk professionals acquire the necessary knowledge to manage current and emerging risks efficiently and effectively. Participants delve into specific aspects of governance and the internal controls identified by international and local regulatory bodies.

Training is practical and interactive. It also includes emerging trends in legislation, regulatory guidelines and sanctions regimes. Sessions draw directly from the trainer's extensive experience of working both in the industry and teaching about it to a wide range of financial institutions.

This anti-bribery and corruption training course will be of interest to AB&C compliance professionals, risk managers and senior management across enterprises.

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