BBA publishes ABC guidance: BBA has published guidance to banks on compliance with the Bribery Act (UKBA) and meeting FCA's expectations in respect of prevention of bribery and corruption (ABC). The guidance summarises the provisions of the UKBA and the Ministry of Justice (MoJ) guidance and principles. It then compares FCA expectations to the UKBA's provisions, and highlights key differences between the UKBA and key global legislation, specifically the US Foreign Corrupt Practices Act (FCPA). It moves on to consider:

  • top level commitment and governance, including governance structure and responsibilities of the Board;
  • risk assessment, including how to determine an adequate risk assessment procedure, giving an example of an end-to-end risk assessment process;
  • due diligence on associated persons and third parties, again including an end-to-end process example;
  • gifts, corporate hospitality and promotional expenditure, with examples of information that businesses may log and use as management 
  • training and communication, including external communications of a bank's policies;
  • monitoring, review and management information; and
  • incident management and reporting.

(Source: BBA Publishes ABC Guidance)