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Transparency International opens new anti-bribery portal

Chris Hamblin, Editor, London, 17 October 2017

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The anti-corruption campaigning group TI is now offering compliance officers and business leaders access to a free online 'tool' that aims to help them understand the complexities of anti-bribery compliance.

With the fact that compliance in this area extends beyond any single national legislation or standard, TI has spent 8 years working on the project with senior compliance officers and lawyers. It presents details of 'best practice' which it draws from the UK's Bribery Act 2010, the American Foreign Corrupt Practices Act 1977, ISO37001 and more.

In the part of the portal that dwells on financial controls, note 7.4.4 proclaims: "No Off-Shore Payments!" It goes on to say that payments for transactions should be in "the country of operation of the country of location of the responsible business unit." Payment in another jurisdiction may be an indication of improper activity and money laundering. The firm in question should impose controls at the very moment that it 'on-boards' a so-called 'third party.' In doing so it must identify the location of the relevant bank account.

Note 7.4.2 exhorts companies to eliminate the use of cash wherever possible. Note 7.4.9.1, on the subject of continuous monitoring, says that responsibility for the monitoring of financial controls should 'be implemented' at each level of every company. For example, supervisors and managers should scrutinise expense payments and reconcile transactions, checking that orders have been recorded as received. Training should emphasise the need for all employees (and particularly those involved in highly risky transactions - explained elsewhere) to be alert to signs of fraud, bribery or other corruption and to know what to do in such situations. Employees and third parties should be encouraged and helped to suggest improvements to financial controls.

New technology receives a mention in 7.4.8. TI is keen on forensic software systems that monitor financial transactions and apply 'red flags' to unusual transactions - for example, an unduly high number of purchase orders placed by an employee just below an approval level that requires a counter-signature. Electronic dashboards come in for some praise as well because they chart the progress of contracts. Analytical software for reviewing and highlighting trends in highly risky transactions (such as expenses claims) is another favourite.

The website is to be found at www.antibriberyguidance.org

 

 

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