The Wolfsberg Anti-Bribery and Corruption Compliance Programme Guidance 2023 is the latest edition of the guidance released by the Wolfsberg Group, a global association of eleven leading financial institutions dedicated to developing standards and principles for the management of financial crime risks.
The guidance is intended to provide a framework for financial institutions to establish and maintain effective anti-bribery and corruption (ABC) compliance programmes. It emphasises the importance of a risk-based approach, taking into account the specific risks faced by each institution and the jurisdictions in which it operates. Similar themes to that of ISO 37301 and the US Department of Justice Guidance on the Evaluation of Compliance Programs.
One of the key components of an effective ABC compliance programme is training. The guidance recognises that training is essential to ensure that employees understand the risks of bribery and corruption and are equipped to identify and report suspicious activities. Training should be provided to all employees, from front-line staff to senior management, and should be tailored to the specific roles and responsibilities of each individual.
The guidance recommends that training should be provided on a regular basis, with refresher training provided at least annually. It should cover a range of topics, including the company’s ABC policies and procedures, the legal and regulatory framework governing bribery and corruption, and practical guidance on how to identify and respond to suspicious activities.
Training should also be interactive and engaging, using case studies and scenarios to illustrate the risks of bribery and corruption in real-world situations. This can help employees to understand the impact that bribery and corruption can have on individuals, communities, and society as a whole, and to appreciate the importance of their role in preventing it.
In addition to providing training to employees, the guidance also emphasises the importance of training third parties, such as agents, intermediaries, and business partners. Financial institutions should ensure that these third parties are aware of the company’s ABC policies and procedures and understand their obligations under relevant laws and regulations. They should also be monitored and audited to ensure compliance.
Finally, the guidance recognises that training alone is not sufficient to ensure effective ABC compliance. Financial institutions must also establish a culture of integrity and ethical behaviour, where employees feel empowered to speak up about suspicious activities without fear of retaliation. This requires leadership and commitment from senior management, who must set the tone from the top and lead by example.
The Wolfsberg Anti-Bribery and Corruption Compliance Programme Guidance 2023 provides a comprehensive framework for financial institutions to establish and maintain effective ABC compliance programmes. Training is a key component of such programmes, and financial institutions should ensure that employees and third parties receive regular, interactive, and engaging training that is tailored to their specific roles and responsibilities. By doing so, they can help to prevent bribery and corruption and promote a culture of integrity and ethical behaviour. Click here for a copy of the guide.
GRC Solutions can help
GRC Solutions offers off-the-shelf and bespoke compliance training modules on a suite of financial crimes topics.
All our courses are able to be customised quickly and economically.
Our training is kept up to date – our legal and compliance teams constantly monitor for relevant developments and incorporate them into our training products.
Anti-Bribery and Corruption Training
This fully customizable online training course is recommended for those who run the risk of being on the receiving end of bribery in both the public and private sectors.
The training is pitched at two levels: the basic modules cater to all employees while the management-only module covers the in-depth knowledge.
A further non-compulsory module teaches staff on how to deal with officials in other countries.