Anti-Corruption Compliance – Understanding the OECD Anti-Bribery Convention, the US’ Foreign Corrupt Practices Act (FCPA), and the UK Anti-Bribery Act: A Practical Hands-On Intensive 2- Day Course

By: Richard Barr, Operational Risk & Back Office Specialist
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Course Description:

Bribery can often damage your business and your reputation. However, your business is not the only victim. The government and the society are affected more, and they are severely undermined by the weakened rule of law and damaged economic and social development. As such, governments are making anti-corruption programs an integral part of compliance. The OECD and its member countries see the core principle in fighting corruption rooted in the principle of free and fair competition. Each bribe offered or accepted compromises this principle.

This two-day training course is a practical look at corruption and current anti-corruption practices at a level that will provide both a clear definition and broad guidelines as to how this scourge can be fought. The in person seminar will discuss and detail issues and checklists to help make setting up your own anti-corruption program easier.

The seminar instructor will use a combination of prepared tuition, examples, discussions, exercises and case studies. For instance, the prominent Siemens case study that will be discussed will examine the corruption scandal and the steps that Siemens subsequently took to recover from this disaster.

This interactive course will offer participants the opportunity to share experiences and plan work within small working groups, providing practice in the application of the techniques and tools, and generating active participation.


Learning Objectives:

  • What is corruption and how to recognize it
  • How to set up your own anti-corruption program
  • Red flags and other warning signs that point to corrupt practices
  • How to implement a process that will allow you to continually improve your anti-corruption measures without overwhelming your organization
  • Steps you can take to better understand your global corruption risks
  • The need for ongoing risk assessments and review
  • Why third-party due diligence can make or break your program

Who Will Benefit:

This practical hands-on training course is designed for all businesses both large and small. The following job titles/ positions will benefit from participating:

  • Ethics and Compliance Executives/Managers
  • General / Corporate Counselors
  • Corporate Legal Executives/Managers
  • Business Division Managers
  • Branch and Regional Management
  • Supply Chain and Procurement Directors, Managers and Their Staff
  • Board Members
  • Risk and Audit Committee Chairs and Members
  • Heads of Market, Credit, And Operational Risk
  • Heads of Risk Management
  • Risk Officers
  • Financial Officers
  • Auditors (External and Internal)
  • Risk Management Consultants

Course Outline

Day One (8:30 AM – 4:30 PM)
Registration Process: 8:30 AM – 9:00 AM Session Start Time: 9:00 AM
  • What is corruption?
    • The corruption problem
    • Understanding corruption
    • Dealing with corruption
    • Current worldwide trends
    • Bribery and corruption risk indicators
    • Solving the corruption problem
  • How is corruption fought?
    • US Foreign Corrupt Practices Act (FCPA)
      • What the FCPA prohibits
      • What makes up a violation
    • OECD Anti-Bribery Convention
      • What the convention covers
    • UK Anti-Bribery Act
      • What the act covers
  • How Do You Recognize Corruption?
    • Corruption defined
    • Most common types of corruption acts
    • Conditions that facilitate corruption
    • How can you combat corruption
  • Compliance/ Bribery Red Flags
    • General red flags
    • Transaction specific red flags
    • Payment red flags
  • The Six Principles for Combating Bribery
    • Proportionate procedures
    • Top level commitment
    • Risk assessment
    • Due diligence
    • Communication and training
    • Monitoring and review

    We will examine each of these principles in detail and explore and discuss the key components of each as well as the sub-issues that need to be addressed. The section will include detailed procedures for meeting the principles.

  • Creating an Effective Anti-Corruption Program
    • A practical approach to creating an effective anti-corruption program
    • Why is a compliance program important
    • Components of a compliance program
    • A timeline for a sustainable program
  • A Practical ‘How To’ Program
    • Hands-on guidance on what companies should consider and include in their compliance programs to ensure that their international partners, agents, consultants, and subsidiaries comply with the law.
      • Consultant due diligence review
      • What should be investigated
      • Due diligence information sources
      • Agreement preparation
      • Consultant information package
      • Internal payment controls
      • Protocols, procedures, education and training
      • Internal audit review

    Participants will be provided with detailed checklists of the key issues that have to be addressed.

Day Two (8:30 AM – 4:30 PM)
  • Illustrative Case Studies
    • Application of the ‘six principles’ through a comprehensive series of illustrative case studies. These studies clearly show how the various aspects of the ‘six principles’ are applied in practice.
    • The illustrative case studies will cover:
      • Facilitation payments
      • Proportionate procedures
      • Joint ventures
      • Hospitality and promotional expenditure
      • Assessing risks
      • Due diligence on agents
      • Community benefits and charitable donations
      • Top level commitment
    • Each case study will involve a detailed group discussion as to the potential solution followed by the presentation of detailed step-by-step procedures.
  • A Global Compliance Checklist
    • We will cover, in detail, the key questions/ issues that a company should consider when putting a global anti-corruption regulatory enforcement strategy in place.
  • Siemens Case Study
  • German based Siemens AG is regarded as Europe's largest engineering conglomerate owing to their diverse range of services and products. It employs over 400,000 people worldwide, working in three main business sectors, Healthcare, Energy, and Information Technology. Most recently it has diversified into the Environmental Industry. With Siemens wide scale scope and diverse business activities, it has in recent years, found it difficult to monitor and regulate its corruption levels.

    In the early 2000s Siemens was at the centre of a very serious corruption scandal, involving cases of non compliance of rules and regulations. This has resulted in top management being investigated and high costs totaling €1.4 billion.

    Subsequently, Siemens reported that it had not done enough to embed its values, rules and guidelines into company practice. The firm has now made considerable changes to its business to integrate transparency and anti-corruption, with a new anti-corruption program, changes in leadership culture, structure, communication, and new systems of embedding rules and values. Siemens wants to assume a leading role in compliance, integrity and transparency.

    This case study examines the corruption scandal and the steps that Siemens subsequently took to recover from this disaster.

Meet Your Instructor

Richard Barr
Richard Barr
Operational Risk & Back Office Specialist

Richard Barr , holds a B.S. in International Business Administration from San Jose State University in California. His professional experience spans over 23 years, 5 of which were spent with Wells Fargo Bank. Another 5 were spent honing his global banking skills, when Richard was intimately involved with International Trade Finance, Real Time Gross Settlement and Cross Border Banking. The past 14 years have been in the private and high-tech sectors providing high-level consulting services, business analysis, project management and training to a wide range of banking clientele across the globe.

Richard has also filled the role of advisor to central banks on payment systems and technical payments issues. Furthermore, key staff members from the Bank of England, South African Reserve Bank, Central Bank of Ireland, Bank Indonesia, European Central Bank and Bank of Portugal have attended training sessions presented by Richard.

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