Wolfsberg Group – ABC Guidance
The Wolfsberg Group has published its updated Anti-Bribery and Corruption (ABC) Compliance Programme Guidance, revising the 2017 version. This guidance aims to foster a culture of ethical business practices and compliance with ABC legal and regulatory requirements. It advocates a risk-based approach for developing and implementing compliance programs to prevent, detect, and report Bribery and Corruption. Key elements include firm-wide ABC policies, governance roles, periodic risk assessments, training and awareness, and monitoring and testing for compliance. The updated guidance incorporates lessons from enforcement actions since 2017, with new sections on identifying and mitigating emerging risks, and aligns with current and evolving legal regulatory expectations, including post-acquisition due diligence.