“Most firms had not properly taken account of our rules covering bribery and corruption…”

“Nearly half the firms in our sample still did not have an adequate ABC risk assessment”

“Management information (MI) on ABC provided to senior management was poor, making it difficult for us to see how firms’ senior management could carry out their oversight functions effectively.”

“The majority of firms had not yet thought about how to monitor the effectiveness of their ABC controls.”

“Firms’ understanding of bribery and corruption was often very limited.”

“There were significant weaknesses in firms’ dealings with third parties used to win or retain business…”

“…few had processes to produce adequate MI, for example, to ensure gifts and expenses in relation to particular clients/projects were reasonable on a cumulative basis…”

“We are concerned that the investment banking sector has been too slow and reactive in managing bribery and corruption risk…”

“…most firms had historically failed to ensure adequate systems and controls to identify, manage and control the bribery and corruption risks to which they were exposed…”

“…none of them had taken action or considered taking action in response to our 2010 thematic review of commercial insurance brokers’ ABC controls or our related enforcement actions against Aon Ltd and Willis Ltd…”

“…some firms still had significant work to do to get an adequate ABC control framework in place. Those firms fell short of our regulatory requirements and we have highlighted where they need to improve. In addition, we are considering whether further regulatory action is required in relation to certain firms in our review…”

“…The FSA and, from next year, the Financial Conduct Authority will continue to focus on ABC issues in this sector and beyond to ensure firms are meeting their legal and regulatory obligations.”

These are extracts from the FSA review into anti-bribery and corruption systems and controls in investment banks published today.

Off the back of it the FSA proposed new guidance for all firms.  The review speaks for itself.

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