SYSC326 assists clients with Anti-Bribery & Corruption ('ABC') framework arrangements, including employee, customer, intermediary and supply chain risk management. On international cases we work with associates, with knowledge of local language, culture, anti-bribery requirements and business practices.
Commercial enterprises (including firms supervised by the Financial Conduct Authority) must comply with requirements of the UK Bribery Act 2010.
Commercial enterprises should implement and maintain effective, risk-based systems and controls to mitigate bribery & corruption risk.
SYSC326 advises clients on anti-bribery & corruption ('ABC') risk, as well as control framework and 'adequate procedures' compliance.
Bribery is a criminal offence. Companies with a UK nexus risk prosecution if inadequate steps are taken to prevent bribery (in the UK or elsewhere).
A defence is available if a commercial enterprise can demonstrate that it maintains adequate (bribery-prevention) procedures.
We assist clients to define and implement bribery-prevention and detection arrangements (e.g. per FCA Handbook - SYSC 6.3 Financial crime).
Firms can find themselves subject of a s166 review initiated by the FCA, or an investigation by the UK's Serious Fraud Office ('SFO').
Penalties, diversion of senior management time and business impact can be severe, involving on-going monitoring in egregious cases.
Associates include experienced Heads' of Financial Crime Investigations; and specialists accustomed to responding to bribery risk.