Anti-bribery and corruption
ABCAlso called ABAC, anti-corruption compliance
Anti-bribery and corruption is the set of policies, controls and training firms use to stop staff and third parties from offering, paying or receiving bribes. It covers gifts, hospitality, intermediaries, political donations and dealings with public officials. Laws such as the UK Bribery Act and the US FCPA make companies liable for bribery.
How it works
A bank's ABC programme starts with a risk assessment by country, sector and business line. It then sets a policy, a gifts and hospitality register, due diligence on agents and suppliers, and approval steps for higher-risk payments. Finance controls check that payments match genuine services. Staff receive regular training and can raise concerns through whistleblowing channels.
Under section 7 of the UK Bribery Act, a company is guilty if a person associated with it bribes to gain business for it, unless it had adequate procedures. That makes the programme a legal defence. The US FCPA reaches bribery of foreign officials and requires accurate books. The EU adopted Directive 2026/1021 in 2026, harmonising corruption offences and corporate fines.
The rules
Creates offences of bribing, being bribed and bribing foreign officials, plus a corporate offence of failing to prevent bribery.
Individuals and organisations with a UK connection, and any company carrying on business in the UKBans bribery of foreign officials and requires issuers to keep accurate books and adequate internal accounting controls.
US issuers, domestic concerns and persons acting in US territoryHarmonises corruption offences and sets maximum corporate fines for bribery of 5% of worldwide turnover or €40 million.
EU member states except Denmark, applied to persons and companies through national law within 24 monthsCommon questions
What is the adequate procedures defence?
Under section 7 of the UK Bribery Act, a company accused of failing to prevent bribery has a full defence if it proves it had adequate procedures to prevent bribery. Ministry of Justice guidance sets six principles, including proportionate procedures, top-level commitment and risk assessment.
Are facilitation payments allowed?
Facilitation payments are illegal under the UK Bribery Act. The US FCPA has a narrow exception for routine governmental action, although many firms ban such payments globally to keep one standard.
How do gifts and hospitality fit into ABC?
Reasonable and proportionate hospitality is permitted, but lavish or frequent gifts can be bribes. Firms set value thresholds, require pre-approval for higher amounts and keep registers. Gifts to public officials usually face stricter limits.
Has US FCPA enforcement changed?
Executive Order 14209 of 10 February 2025 paused new FCPA actions for review. In June 2025 the Justice Department issued new guidelines focusing enforcement on cases tied to cartels, US competitiveness and national security. The statute itself was not changed.
