Dost Mushtaq, FICA

Failure to meet third party due diligence obligations can expose organisations to corruption risk. As most corruption enforcement action has centred on bribes made by third parties, the organisation’s ability to readily identify which of its third parties represent heightened risk is critically important.

Going beyond a culture of compliance and its associated policies and procedures, creating an ethical culture necessitates a long-term and sustained effort. Convincing cultural change revolves around the themes of accountability and responsibility with ethical metrics integrated into performance, promotion and compensation plans.

Despite the hopes of many, the FCPA Guide on what constitutes an effective compliance programme is not legally binding, nor does it provide a safe harbour for companies. What it does do, however; is serve as a wake-up call for those boards and senior management who have permitted their anti-corruption compliance programs to languish.

Emerging markets may expose private equity firms to greater corruption risk. Given the speed with which private equity deals are reached and consummated, it is critical that real and meaningful due diligence procedures and compliance programmes are in place.

Overview of the emerging compliance issues around the burgeoning use of social media, and how compliance professionals and firms can stay abreast of the issues in this fast-moving area.