The Wolfsberg Group's ABC Programme

The Wolfsberg Group has updated its Anti-Bribery and Corruption Compliance Programme Guidance to encourage ethical business practices and compliance with legal and regulatory obligations. The recommendations identify areas of high risk to build and implement compliance programs using a risk-based approach. The important components include a firm-wide ABC policy, governance with top management access, regular risk assessments, training and awareness, and monitoring and testing for compliance.

The Guidance contains the latest section on identifying and mitigating emerging risks and goes on to extend customer and transaction corruption concerns. It also takes into account the lessons learned from enforcement actions since 2017. Additionally, the advice is consistent with current legal and regulatory requirements and includes advice for post-acquisition due diligence and comprehensive risk assessment.