Anti-bribery and corruption (ABC) compliance is not something that can be left on autopilot. As global regulations grow more stringent and enforcement becomes more aggressive, businesses must ensure their ABC programmes are robust, responsive, and relevant. Failing to maintain a healthy compliance culture can expose your organisation to legal, financial, and reputational risks.
So, how do you know when your ABC compliance programme needs a revamp? Here are the warning signs you should never ignore.
1. Outdated Policies and Procedures
If your organisation hasn’t reviewed or updated its ABC policies in the last two years, that’s a red flag. Laws and regulatory expectations change rapidly, especially in high-risk jurisdictions. Outdated documentation could leave gaps in your controls, fail to reflect evolving bribery risks, or miss new legal obligations.
What to do: Schedule annual reviews of all compliance policies and procedures, and ensure they are aligned with current legislation, industry standards, and the specific risk profile of your organisation.
2. ABC Training Is Only Provided at Onboarding
One-off training at the start of employment is not enough. Employees can forget key procedures or remain unaware of new threats and evolving regulations. If ongoing training is not part of your compliance culture, your team may be ill-equipped to recognise and report bribery and corruption risks.
What to do: Introduce regular refresher courses and tailored training sessions, particularly for staff in high-risk functions such as procurement, sales, or operations in emerging markets.
3. Expansion into High-Risk Markets Without Enhanced Measures
When entering new or high-risk territories, your bribery and corruption risk exposure increases. If your organisation expands without implementing additional controls or conducting a fresh risk assessment, your compliance programme may no longer be fit for purpose.
What to do: Before expanding, perform due diligence, review local laws, and implement enhanced compliance procedures. Update your risk assessment to reflect new business activities and ensure adequate resources are allocated to manage the risk.
4. Weak Third-Party Due Diligence
Third parties, including agents, suppliers, and consultants, often pose the greatest corruption risk. If your current due diligence process is superficial, inconsistent, or lacks proper documentation, it could expose your company to liability for a third party’s misconduct.
What to do: Strengthen your third-party risk management by standardising the due diligence process, categorising third parties by risk level, and re-evaluating them periodically. Always maintain detailed records of checks performed and any red flags identified.
5. Unclear Compliance Responsibilities
When no one knows who is ultimately responsible for anti-bribery compliance within the company, implementation and enforcement of policies become ineffective. A lack of accountability leads to confusion and inconsistent application of controls.
What to do: Clearly define and assign compliance roles and responsibilities across all levels of the organisation. Designate a compliance officer or team to oversee the ABC programme and ensure they have the authority and resources to act.
6. Poor Internal Reporting Culture
If employees are unsure about how to report bribery concerns, or worse, don’t trust the reporting channels available, this is a serious issue. A healthy compliance culture depends on open communication and the ability to raise concerns without fear of retaliation.
What to do: Promote a speak-up culture by offering multiple, confidential reporting channels. Regularly communicate these options to staff and reassure them of protection under your whistleblowing policy.
7. No Improvement After Past Incidents
Has your organisation faced an ABC-related issue in the past, but failed to make meaningful improvements since? Ignoring lessons learned from past events is a recipe for repeat violations and escalating penalties.
What to do: After any incident or audit finding, conduct a root cause analysis and use the insights to strengthen your programme. Revise procedures, enhance training, and document all corrective actions taken.
Why You Should Act Now
A weak ABC compliance programme not only increases your risk of regulatory penalties but can also damage your brand, disqualify you from contracts, and result in criminal charges for senior staff.
Building and maintaining a strong ABC programme is not optional—it’s a business necessity. Compliance should be seen as an enabler of sustainable growth, reputation management, and long-term value creation.
Strengthen Your Compliance with CompFidus Ltd
If you’ve identified one or more of these warning signs in your organisation, it may be time to conduct a comprehensive review of your ABC compliance framework. CompFidus Ltd helps companies of all sizes assess, improve, and implement effective compliance strategies.
From policy development to third-party risk management and customised employee training, our team of experts provides hands-on support to keep your business aligned with regulatory expectations and protected from risk.
Get in touch today to safeguard your operations and protect your business integrity.