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Wolfsberg Group Publish updated 2023 ABC Guidance


Today Apr 17, 2023, the Wolfsberg Group is publishing its updated Anti-Bribery and Corruption Compliance Programme Guidance.

The 2023 document updates the 2017 version and promotes

  • A culture of ethical business practices and
  • Compliance with ABC legal and regulatory requirements.

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.

The guidance can help the industry mitigate Bribery and Corruption risks by using elements including but not limited to:

  • An applicable firm-wide ABC policy;
  • Governance with roles and 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; and
  • 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 guidance incorporates learnings from enforcement actions since 2017 with updates to the red flags section and expands the area on customer and transaction corruption risks.

The document includes the need for financial institutions' programmes to evolve continuously and a new section on identifying, reporting, and mitigating emerging Bribery and Corruption risks.

Finally, the guidance is aligned with current and evolving legal and regulatory expectations with additional guidance for post-acquisition due diligence, including

  • Guidance for financial institutions to include a holistic risk assessment and management as part of their control frameworks.

The guidance is here ABC Guidance 2023.pdf

The Executive Summary is here -


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