The festive season is for many companies a season of reflection and celebration. Celebration of relationships for instance which often comes with cards, presents, dinners, lunches and more. Looking at discussions on LinkedIn it’s still a topic for discussion. Taking your business partners out for a meal, sending a case of wine or organizing a lavish Christmas party is a very normal way of celebrating a successful year and looking forward to future cooperation.
That brings ABC policies into the picture. Most companies will have some sort of guidance on anti-bribery and corruption, even small and medium enterprises nowadays cannot do without guidance notes, instructions and policies. Policies for whistle blowing and self-disclosure become more common and more needed as was highlighted at a recent ACAMS webinar as well < http://www.acams.org/free-webinar-library/ >
Focusing on the role of financial institutions, the speakers indicate a very clear link with KYC. Knowing Your Client is still key and FIs often still forget what it takes to truly know your client.
Irrespective of good policies, systems to detect suspicious transactions and RegTech developments, KYC in essence still means that an FI needs to understand the client: who are the directors, what is the nature of the business, what suppliers and agents are used, who are the customers and in which countries do they reside etc. etc.
Good systems for transaction monitoring and detection of trade based money laundering in combination with a high staff awareness, will support FIs to detect bribery and corruption. Bear in mind that bribery and corruption often lead to money laundering; FIs need to understand this and need to ensure the entire operational organization is aware of this. Knowing Your Client on an operational level is for every FI crucial, also to detect bribery and corruption.