FCC RegUpdate

On April 17, 2023, the Wolfsberg Group published the updated Anti-Bribery and Corruption Compliance Programme Guidance. This document updates the 2017 version of the ABC guidance.
The guidance is a risk-based approach for the adequate development and implementation of compliance programmes to prevent, detect, and report acts of bribery and corruption and identify areas of elevated risk. This guidance can help the industry mitigate bribery and corruption risks by using elements including, but not limited to:
1. An applicable firm-wide ABC policy
2. Governance with roles and responsibilities and access to top management
3. Periodic risk assessment to assess the nature and extent of the bribery and corruption risks, the establishment of a control environment covering risks associated with anything of value, third party providers, customer related transaction risks, investments, and acquisitions
4. Training and awareness, including the sharing of lessons learned from internal and external events, are necessary for the continuous evaluation of the compliance program’s adequacy.
5. Monitoring and testing for compliance with controls to identify failure to act in a manner consistent with the financial institution’s business principles, policies, codes of conduct, or applicable laws or regulations

The guidance incorporates learnings from enforcement actions since 2017 with updates to the red flags section and expands the section on customer and transactional corruption risks.