Bribery & Corruption

As the tools and resources available to counter the threat of bribery & corruption are increasing, so are regulators’ expectations for firms to implement robust anti-bribery and corruption (ABC) frameworks.

Faced with complex and overlapping legal frameworks, it is imperative for firms to uplift their controls and adopt a comprehensive ABC strategy to protect their business, its customers, employees and investors from financial loss and reputational damage.

The complexity of calibrating ABC controls

Several common business practices can expose your firm to ABC risks in the absence of proper due diligence, including:

Political donations
Facilitation payments
Gifts, entertainment and hospitality
Conflicts of interest
Charitable donations
Commercial sponsorships
Goodwill payments / legal statements
Speaker’s fees
Client / third-party training programmes

Moreover, in some jurisdictions such as the UK, failing to prevent bribery and corruption is itself an offence. This means that ineffective or deficient anti-bribery and corruption programme are grounds for enforcement action, even in the absence of specific instances of B&C.

With an increasingly globalised supply chain, firms should take action to protect themselves against the B&C risks posed by third parties. This includes specific risks represented by associated persons, including: Introducers, Agents and Lobbyists.

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Moreover, in some jurisdictions such as the UK, failing to prevent bribery and corruption is itself an offence.

This means that ineffective or deficient anti-bribery and corruption programme are grounds for enforcement action, even in the absence of specific instances of B&C.

With an increasingly globalised supply chain, firms should take action to protect themselves against the B&C risks posed by third parties. This includes specific risks represented by associated persons, including:

Introducers
Agents
Lobbyists

How Plenitude can help

Plenitude can help your continuous effort to limit and manage the risk and impact of B&C. We could help you understand the actual risk exposure and support you with the design and implementation of effective, proportionate and sustainable controls based on the following principles:

Understanding

the actual risk exposure and effectiveness of controls in place to mitigate B&C.
Proportionality

design and implementation of proportionate controls embedded into business processes.
Top-Level Commitment

adopting a clear Risk Appetite Statement with supporting metrics and management information to provide guiderails and measure adherence to risk appetite within the firm.
Due Diligence

applying proportionate due diligence at onboarding and ongoing based on a good understanding of the risk profile applicable to customer and third-party relationships.

Our team of experts can support your firm at every step with our services including:

Independent Assessment

executing a proportionate assessment of your AB&C controls or programme to manage compliance in readiness for regulatory reviews or to take proactive action.
Supporting firms through S166 Reviews (firm-side)

or conducting S166 Reviews on behalf of the FCC on the basis Plenitude is appointed to the Skilled Person Panel for Lot E: Financial Crime. Guiding firms through the remediation process linked to enforcement action or regulatory review.
Risk Assessment

design and conduct a comprehensive risk assessment to assess your AB&C risk.
Assess and enhance ABC related policies, standards and procedures.
Designing and implementing a comprehensive AB&C programme.

The Human Cost of corruption

There is a social, political and regulatory imperative for financial institutions to take diligent and rigorous steps to mitigate bribery and corruption risks in order to prevent the facilitation of unfair competition practices. Corruption has also far-reaching systemic consequences, as it undermines rule of law and damages social and economic development.

Our Services

Our capabilities address the entire spectrum of financial crime risks and, as a full-service provider, we can meet all of our clients’ needs in order to deliver a truly integrated consulting service. We can assist with a wide range of needs, including independent assessments, policy and standards enhancement, risk assessments, specialist tech and data support, and remediation and transformation program design and execution. No matter what the requirement, we are here to help.

Discover more about our services and see why our integrity, passion and delivery excellence have been praised by so many clients.

Advisory & Transformation

Clients typically engage us when they have been subject to regulatory feedback, are expecting a visit from the regulator, or have concerns and want to take proactive action. Regardless of the situation, we can help.

S166 Skilled Person Services

Under the Financial Services and Markets Act 2000 (FSMA), the FCA’s Section 166 review is an independent review by a third party (a ‘skilled person’) about aspects of a regulated firm’s activities where the FCA has concerns or requires further analysis.

Fraud Practice

Global regulatory shifts are compelling financial organisations to prioritise fraud prevention more than ever, and rising fraud complexity highlights the critical role of operational teams as the first line of defence.

Digital Assets Practice

In slightly more than a decade, the digital assets industry has skyrocketed to a market cap of over 2 trillion USD, bringing innovations poised to revolutionise monetary systems, financial services and beyond.

Technology Advisory Services

Regulated firms face a constant battle against financial crime, and technology plays a crucial role in this fight. However, leveraging technology and keeping up with innovation comes with its own set of challenges.

Data Analytics Services

Data quality, siloed systems, and the ever-evolving tactics of criminals make effective data analysis a constant battle. Firms need to break down these silos to get a holistic view of customer activity and identify hidden patterns that might indicate a financial crime threat.

KYC Managed Service

The regulatory landscape continues to evolve placing increased regulatory pressure and demand on institutions to meet their KYC/CDD compliance obligations, often at significant cost.

RegTech Products

Our RegTech subscription products enable our clients to manage financial crime obligations, country and client risk more effectively while reducing internal risks, costs and resource demands.