Exiger's ABC Roundtable: Key Takeaways

Exiger recently hosted its first virtual Anti-Bribery and Corruption (ABC) Roundtable under Chatham House Rules bringing together senior-level ABC Practitioners from a range of global banks to discuss the current risks and challenges faced by their ABC teams. Key discussion topics included an overview of recent regulatory and industry developments, emerging trends across the globe and the current challenges in implementing an effective ABC programme.

Exiger provided an overview of regulatory developments in the ABC space across the globe and highlighted the increased focus in the following areas:

Foreign bribery / extra territorial reach
International collaboration / Information sharing
Third party and supply chain risk (incl. ESG/Modern Slavery, Cyber)
Corporate transparency (incl. beneficial ownership)
Adequate procedures, books & records provisions
Whistleblowing
Magnitsky type sanctions

Despite the pandemic, regulators and law enforcement authorities have been actively updating their guidance providing additional clarity around their expectations. Some noteworthy updates in the past year included:

The U.S Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) released the second edition of its Foreign Corrupt Practices Act (FCPA) resource guide and the Biden administration announced a comprehensive national security strategy to combat corruption.
U.K introduced the Global Anti-Corruption Sanctions Regulations and continued its pursuits around Unexplained Wealth Orders (UWOs), corporate transparency and register reforms.
Germany introduced the Corporate Sanctions Act with plans to roll out its Supply Chain Act in 2023.
China introduced additional cross border data restrictions further increasing the complexity for multi-jurisdictional organisations operating in China.