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Wolfsberg Group publishes its updated Anti-Bribery and Corruption Compliance Programme Guidance

Author: Warren​ Coles
Date: April 2023

On April 17th the Wolfberg Group, an association of 13 global banks set up to develop frameworks and guidance for the management of financial crime risks (notably KYC, AML and Counter Terrorist Financing policies) announced an update to its 2017 Anti-Bribery and Corruption Compliance Programme Guidance.

The new document contains several key updates:

  • Changes to the red flags section,
  • An expansion on the part on customer and transaction corruption risks,
  • A statement on the need for financial institutions to have programmes that are continually evolving,
  • The addition of a section that addresses how to identify, report and migitate new risks,
  • Alignment with the most recent regulatory changes,
  • A section on how financial institutions, as part of their control frameworks, should include a holistic risk assessment.

The document itself, through a risk-based approach, is designed to provide guidance to the financial services industry on how to develop, implement, and maintain an effective Anti-Bribery & Corruption (ABC) Compliance Programme, 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 overall objective of the Guidance is to promote a culture of ethical business practices and compliance with ABC legal and regulatory requirements.

The Guidance can be accessed here and the Executive Summary here.

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Warren​ Coles
Warren is a growth and digital marketing veteran with over twenty years' experience across SaaS and the wider technology area in general.