Brain training: 10 things you need to know about...

Brain training - 10 things you need to know about

...anti-bribery and corruption regulations

1 As meaty Financial Conduct Authority fines handed out to the likes of Aon, Besso, JLT and Willis show, you don't have to be a top FIFA executive to fall foul of anti-bribery and corruption regulations

2 Contrary to what you may have inferred from the Jackson 5 song of that name, there's nothing easy about ABC. Pitfalls abound for the unwary

3 Be sure whoever is charged with managing ABC risk in your firm has the appropriate experience and knowledge - or is closely advised by someone who does

4 All employees need to be alert to ABC risk. Provide detailed reference materials explaining what is required and how to deliver it on a day-to-day basis

5 Employees need appropriate and targeted training in sound ABC procedures - backed by ongoing monitoring and testing

6 A recent FCA thematic review criticised firms' failure to take a holistic view of ABC. It's essential to ‘join the dots', not just tick the boxes

7 The FCA is looking for a coherent risk-based approach that routinely highlights high risk transactions and targets them with ‘enhanced due diligence'

8 ABC considerations need to be a key part of the due diligence process undertaken before entering into any new relationship

9 You will be expected to prove you are managing financial crime prevention proactively and responding to the true risks identified in each relationship

10 As with every other aspect of regulatory compliance, you will not get credit for anything you do unless you write it down - documentation is crucial

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