Anti-Bribery & Corruption: Managing Emerging Risks

Learn the adequate and effective management of emerging risks with this Anti-Bribery and Corruption training course

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A one-day course

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Download: Course Outline

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. At Redcliffe Training, our anti-bribery & corruption training course covers the following:

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
Anti-bribery training course case studies:
- McKinsey and the Opioid Crisis
- Airbus Corruption Inquiry

Session 2: Developments in Benchmarking

This anti-bribery training course 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. This anti-bribery and corruption training course covers the following elements in Session 3:

In Session 3 of this anti-bribery & corruption training course, we will explore these recommendations in greater detail, beginning with:

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
Anti-bribery & Corruption Training 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 Training Course 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 training course participants 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
Anti-Bribery and Corruption Training Course 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
Anti-bribery & corruption training covers 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 covers:

Societal trends
Impact of social media
Shareholder activism
This anti-bribery & corruption training course assesses 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

At Redcliffe, our anti-bribery and corruption course is led by a Chartered Certified Accountant with an MBA from Cass Business School. With over 20 years dedicated to internal audit, product control, corruption risk management and SOX, this specialist has worked for major global banks in London thus further highlighting his ‘ground level’ experience. In addition, this trainer has spent several years at a major bank as a Business Manager for global markets.

Over the last six years, this dedicated anti-bribery & corruption training 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.

Anti-bribery & corruption training helps participants 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.
Anti-bribery and corruption training covers the importance of having an adequate AB&C reputational risk management framework.

Redcliffe’s anti-bribery & corruption training course provides a systematic and comprehensive analysis of the many current challenges posed by risks. This includes the interaction with other financial crime risks.
Sessions include anti-bribery & corruption benchmark practices, risk-sensitive frameworks, third-party due diligence and international regulatory guidelines.
Courses are practical and highly interactive. You will delve into several highly relevant case studies, exercises and discussion points surrounding anti-bribery regulations.
The program is designed and delivered by an industry professional with extensive experience in the banking and financial services sector. Leading financial crime, trading risk management and audit training across major global business and product lines, participants attending anti-corruption training for employees are in knowledgeable hands.
Participants can be confident that this anti-bribery and corruption training course is grounded in real-world expertise and industry best practices.

Redcliffe anti-corruption training for employees will provide value 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 fully understand risks which might impact their operating environment and how they might be managed
Anti-bribery & corruption training is also recommended for risk professionals who need to improve their AB&C knowledge with anti-corruption compliance best practices.

Redcliffe's anti-bribery and corruption training course is designed to help individuals recognise situations involving bribery and corruption, and ensure AB&C risk professionals know how 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 training will appeal to AB&C compliance professionals, risk managers and senior management across enterprises. Please note that anti-bribery & corruption training is available online or can be delivered in-house to your organisation.

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