On 4 July 2017, the Wolfsberg Group published updated guidance on how financial institutions should construct an effective anti-bribery and corruption compliance programme, together with a statement that summarises the changes made and the reasons for those changes.

The guidance updates the anti-corruption paper published by the Wolfsberg Group in August 2011 – It has been developed in collaboration with the Basel Institute on governance and with input from Transparency International.

The guidance focuses on how financial institutions can manage their own bribery and corruption risk in respect of the behaviour of their employees and third parties acting on their behalf. The guidance makes substantive changes to the following areas:

• The definition of government/public officials.
• The definition of intermediaries and associated controls.
• Risk management of principal investments and joint ventures.
• Offers of employment and work experience.
• The reduction of focus on customer-related anti money laundering provisions.

The guidance also highlights the importance of taking a risk-based approach, reflecting, for example, the greater risk posed when pursuing new business from a government or commercial entity rather than an individual customer and, generally, when interacting with public officials.

The appendix to the guidance includes examples of red flags that financial institutions may wish to take into account when designing an anti-bribery and corruption compliance programme.