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Financial crime issue predictions for 2021 & CULTURE

28/01/2021

I was interested in the following prediction from Allen Overy [https://www.allenovery.com/].

Culture:

  1. The only defence for corporates faced with bribery or facilitating tax evasion allegations is 'adequate' or 'reasonable' procedures.

  1. We expect to see a focus on

  • The non-executive and senior board members' tone from the top and corporate culture as authorities probe just how embedded compliance policies and procedures are.

Senior managers may also be asked about the:

  • 'tone from the middle' or,
  • 'tone from within'.(FCA term)

READ PG-55

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