Implementing anti-bribery measures in investment banks

The FSA’s recent report into anti-bribery systems and controls in investment banks found that the 15 institutions in its thematic study were too slow and reactive in managing their bribery and corruption risks. Steven Francis looks in detail at some of the more difficult aspects of bribery and corruption controls, and considers how firms might respond generally to thematic reviews.

Steven Francis is a partner in the regulatory and business crime group at RPC (Reynolds Porter Chamberlain) and may be contacted at steven.francis@rpc.co.uk.

In these difficult times, when the causes of the financial services industry’s troubles are still being debated, bribery may appear of marginal materiality, especially in investment banks, which have so many bigger questions to answer. The doubters may point to the fact that, under the latest government proposals, the anti-financial crime agenda is not to be one of the FCA’s statutory objectives, being relegated to a matter to which it should have regard.