This Anti-Corruption Helpdesk brief was produced in response to a query from one of Transparency International’s national chapters. The Anti-Corruption Helpdesk is operated by Transparency International and funded by the European Union.
We are developing a benchmarking tool to assess anti-corruption and transparency standards in global banking institutions. Please provide information on banking practices in relevant areas, such as controls concerning political financing, lobbying, conflicts of interest, third party due diligence, compliance with the Foreign Corrupt Practices Act (FCPA) and engagement with politically exposed persons (PEPs). Please provide commentary on the public reporting expectations of banks on their practices.
- Anti-corruption standards and practices
- Public reporting standards and practices
There is a substantial pool of publicly available resources published by credible industry and global standards bodies on anti-corruption practices in banks. The corruption risks affecting banks can be categorised into two main areas: customer-related risks, for example, customers who seek to launder the proceeds of corruption through a bank, and the direct risks stemming from the interaction between banks and public officials, such as lobbying activity. Guidance for banks on how to address these risks is commonly separated into distinct areas of anti-money laundering and anti-bribery and corruption. However, the two subjects share a common basis, which encompasses standards in governance, risk assessment, internal controls, awareness and training, investigation and reporting and monitoring and review. This Helpdesk Answer outlines best practice guidance in these areas, which together constitute a comprehensive set of standards for combatting the full spectrum of corruption risks to which banks are exposed. To date, global banks have performed poorly in transparency indices. Nevertheless, there is momentum toward improved transparency, as shown by the introduction of country-by-country reporting requirements in the EU. There is also guidance available on standards of public reporting against which bank practices in areas relevant to corruption issues can be assessed.
Thomas Shipley, Transparency International, firstname.lastname@example.org