Anti-Corruption

Transparency International

CORRUPTION PERCEPTIONS INDEX (2022)

This index, which ranks 180 countries and territories by their perceived levels of public sector corruption accordingly to experts and business people, uses a  scale of 0 to 100, where 0 is highly corruption 100 is very clean.  More than 2/3 of countries scored below 50 on 2022 year's CIP.  It reveals that continued failure of most countries to significantly control corruption is contributing to a crisis in democracy around the world.  While there are exceptions, the data shows that despite some progress, most countries are failing to make serious inrods aainst corruption.


Anti-bribery and Corruption Obligations

United States: Foreign Corrupt Practice Act (FCPA)

United Kingdom: United Kingdom's Bribery Act 2010 (UK Bribery Act)

Hong Kong: Hong Kong Prevention of Bribery Ordinance (PBO)

Case Study

SEC Charges Credit Suisse with FCPA Violations

 SEC Charges Deutsche Bank with FCPA Violations Related to Third-Party Intermediaries

Ex-bank manager charged by HK ICAC for accepting bribes from clients over stock trading

Goldman banker goes on trail over Malaysia's 1MDB  corruption scandal

Petrofac paid Serious Fraud Office (SFO) US$105 million to settle "deeply regrettable" bribe charges

Ex-HSBC employee charged with consipiracy to accept bribes

PEPs

Material PEP: an individual who holds a current ministerial, political or executive position and who is acting as a director, shareholder, investor or connected person of a client entity; or, an individual who is classified as a PEP given their close association with a material PEP, e.g., spouse, sibling, child or close business partner.

Non-Material PEP: an individual who holds/held a PEP position(s) which is relatively non-prominent or has limited influence that he/she could exercise.

Industries are more susceptible to corruption 

Policies and Procedures