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Deloitte Bribery and Corruption Survey 2019

Taking all reasonable steps

Bribery and corruption is a multi-dimensional issue, where incidents can undermine an organisation’s reputation, culture, regulatory standing and profitability. Beyond organisational borders, this force damages people, communities, economies and countries.

We are seeing significant developments in Anti-Bribery and Corruption (ABAC) regulation, research and trends across Europe and the broader global community, with this rapid evolution echoing current conditions of global uncertainty. Regulators and enforcement agencies are actively advocating agendas to minimise the risk of not just bribery and corruption, but also money laundering, terrorist financing, corporate misconduct and fraud.

In line with these developments, Ireland’s Criminal Justice (Corruption) Act 2018 has repealed and replaced previous legislation on bribery and corruption, some of which was over 100 years old. The investigation and prosecution of perpetrators has now become a reality.

The Act has introduced a new corporate corruption offence whereby a corporate shall be found guilty of an offence if it is committed by an employee or third party.

Our survey, however, found that although 49% of respondents see reputational damage as the key downside of a bribery or corruption, only 18% consider bribery and corruption a key risk. This suggests we still have some way to go to keep pace with international trends.

Organisations need to adopt a proactive, holistic approach to managing the risk of all financial crimes. The most successful ABAC programmes properly balance prevention, detection and response activities and focus on identifying how bribery and corruption occur in practice, rather than just thinking about the broad risk. Already, clients we work with are using automated due diligence software, data analytics advancements in detection, and bespoke training to help inform their response.

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