The revised anti-bribery and anti-corruption framework introduces a focused local risk assessment, which targets more exposed functions and provides for the recording of effective local solutions. It continues to mitigate the risk of outgoing payments to third parties, especially to brokers, consultants and other intermediaries, for the purpose of acquiring or maintaining business.
It helps the business to identify unusual payments and implement appropriate controls. It also lays out procedures for reviewing and recording gifts, entertainment and other advantages. The policy and guidance outlines the requirements for associated persons’ due diligence before commencing the relationship and on a risk-based approach throughout the relationship.