On 17 April 2023, the Wolfsburg Group published an updated version of its anti-bribery and corruption compliance programme guidance.

The publication is designed to provide guidance to the financial services industry on how to develop, implement and maintain an effective anti-bribery and 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 conducts business.

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 identifies areas of elevated risk.

While no ABC compliance programme can prevent or protect against bribery and corruption risks completely, and there is no one size fits all solution, the guidance can help the financial services industry mitigate bribery and corruption risks by using elements including but not limited to:

• An applicable firm wide ABC policy.
• Governance with roles, responsibilities, and access to top management.
• Periodic risk assessment to assess the nature and extent of the bribery and corruption risks, the establishment of a controls environment covering risks associated with anything of value, third party providers and customer related transaction risks, investments and acquisitions.
• Training and awareness including the sharing of lessons learned from internal and external events for continuous evaluation of the compliance programme adequacy.
• 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/ applicable laws or regulations.

The updated guidance incorporates learnings from enforcement actions since 2017 with updates to the red flags section and expands the section on customer and transaction corruption risks. It has also been aligned to current and evolving legal regulatory expectations with additional guidance for post-acquisition due diligence, the inclusion of guidance for financial institutions to include a holistic risk assessment and management as part of their control frameworks.