Anti-Bribery & Corruption: Managing Emerging Risks

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

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A one-day course

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Download: Course Category Brochure | 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.

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
Case Study: McKinsey and the Opioid Crisis
Case Study: Airbus Corruption Inquiry

Session 2: Developments in Benchmarking

This session provides an overview on some of the best practices being adopted in AB&C.

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.

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 AB&C 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
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
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.

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 & 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 & Bribery & Corruption
- Trade & Illicit Financial Flows
Case Study: The Wagner Group & Sudan Gold
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.

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

Our anti-bribery and corruption course trainer is a Chartered Certified Accountant with an MBA from Cass Business School, who has over 20 years experience in internal audit, product control, corruption risk management and SOX, working for major global banks in London. In addition, the trainer also spent several years as a business manager for global markets at a major bank. He spent the last 6 years training financial crime risk for several banks and financial institutions, in the UK and in more than 35 countries across the globe.

Participants will develop a greater appreciation and understanding of:

Emerging trends that will impact their AB&C 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.
The 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 AB&C interacts 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.

Our anti-bribery and corruption training is designed to provide a systematic and comprehensive analysis of the many current challenges posed by AB&C risks, including their interaction with other financial crime risks.
Our course covers AB&C benchmark practices, risk-sensitive frameworks, third-party due diligence and international regulatory guidelines.
The course includes several highly relevant case studies, exercises and discussion points on anti-bribery regulations, and as such will be highly practical and interactive
Our anti-bribery and corruption course is developed and delivered by a professional trainer with extensive experience in banking and financial services, covering trading risk management, audit and financial crime training across major global business and product lines.

Our anti-bribery training course is suitable for:

AB&C risk professionals in general.
Managers and risk professionals wishing to establish an AB&C risk management, anti-bribery and corruption 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.
Anti-bribery courses are also recommended for risk professionals who need to improve their AB&C knowledge with anti-corruption compliance best practices.

Our anti-bribery and corruption training is designed to ensure that AB&C risk professionals acquire the knowledge necessary to manage current and emerging risks within their organisations, efficiently and effectively. The course focuses on those topics and specific aspects of governance and internal controls that have been identified by international and local regulatory bodies, as well as emerging trends in legislation, regulatory guidelines and sanctions regimes.

The course draws on the trainer’s extensive experience working with and delivering courses for a wide range of financial institutions. As such, it will be both practical and interactive and should be of interest to AB&C compliance professionals, risk managers and senior management in all types of enterprises.

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