12th May 2014

Helping banks tackle bribery and corruption

Written by Justine Walker

This week we published our updated Anti-Bribery and Corruption Guidance giving banks greater insight into how to deliver on their regulatory and compliance responsibilities.

The BBA first published the guidance in 2011 to provide banks with practical procedures and recommendations for how to comply with the 2010 Bribery Act. This section of the text remains unchanged.

But the new document has been expanded to reflect key developments, such as increased regulatory scrutiny and the Financial Conduct Authority’s thematic review, and balances them with the requirements of the Bribery Act.

Handling third party relationships is a good example of this. The sheer volume and diversity of risk within such relationships makes it vital that banks adopt a clear and recorded risk-based approach. The addition of examples of third party due diligence offer banks practical solutions to dealing with these concerns.

The Bribery Act also outlined the need for a cultural shift in the industry’s approach to the issue. Banks are already working hard to introduce the correct level of ‘tone from the top’ and increasingly ‘tone from the middle’ changes. The updated guidance draws on emerging banking practice to further push this forward.

It now includes some thoughts the benefits of establishing “business line champions” and similar measures to implement robust anti-bribery and corruption controls. This is another step in the right direction to installing sound and ethical procedures.

Soon after the Act was introduced, the BBA established a working party to help banks share their experiences and talk to regulators and governments with one voice to ensure a fair, proportionate and ethical system. Reflecting these conversations, the new text also covers issues such as approaches to risk assessments, key performance indicators and cross overs with the new whistleblowing rules.

For more information about the guidance, please do not hesitate to contact me directly –  Justine.walker@bba.org.uk.

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