Publication of the ABC Guidance

The Wolfsberg Group has released an updated its Wolfsberg Anti-Bribery and Corruption Compliance Programme Guidance to promote ethical business practices and compliance with legal and regulatory requirements.
The guidance is designed to provide guidance to the financial services industry on how to develop, implement, and maintain an effective ABC Compliance Programme. The overall objective of the Guidance is to promote a culture of ethical business practices and compliance with ABC legal and regulatory requirements. The Guidance replaces the 2017 Wolfsberg ABC Compliance Programme Guidance and should be read in conjunction with applicable legislation, regulation, and guidance issued by authorities in the jurisdictions in which a financial institution (FI) conducts business.
The Guidance emphasizes the importance of a RBA for the adequate development and implementation of programmes to prevent, detect, and report acts of Bribery and Corruption. FIs should periodically assess their business model including the locations in which they do business, their customer base, products and services, and the means by which they obtain and retain business such as through the use of intermediaries and engagement with other third parties. Periodic assessments will enable FIs to identify inherent risks and adopt policies, procedures, and controls that are proportionate to the identified risks.
The Guidance outlines the key elements of an effective ABC Compliance Programme, including a firm-wide policy, governance, roles and responsibility, risk assessment, establishment of a control environment, customer-related transaction risks, principal investments and controlled fund acquisitions, training and awareness, and monitoring and testing for compliance with controls. The Guidance also defines corruption and bribery and provides additional sources on definitions of corruption.