Time to get ISO 37001 Certified – The Process, Part 1

Shifting a light on anti-Bribery and anti-corruption methods, our sister brand ABAC™ Centre of Excellence tells us how key is ISO 37001:2016 Anti-Bribery Management System Certification is for public, private, and non-profit organisations across the globe and explains the process behind certification. At CRI®, we believe it is important as it provides a key layer against threats of bribery, corruption, fraud and other security concerns. It also sets an organisation apart from its peers as a model for ethical behaviour and compliance. After all, consider the benefits: Certification adds a distinct level of credibility to the organisation’s management systems and ensures that the organisation implements a viable anti-bribery management program utilising widely accepted controls and systems.

It assures management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. ISO 37001:2016 certification also protects the organisation, its assets, shareholders and directors from the effects of bribery. But what, exactly, is the process for getting ISO 37001:2016 certified by ABAC Group™? Once your organisation has submitted questionnaire information and completed the approval and contract stage, the certification cycle is ready to begin.

Step 1: Audit confirmation

An audit plan will be developed with your organisation and confirmed to the Certification’s Body Assessment Team at least three months before the organisation’s first audit.

Step 2: Pre-assessment audit (optional)

The organisation can opt to perform a pre-assessment audit to identify any possible gaps between its current management system and the standard requirements. This audit is optional and helps the organisation check its preparedness for the stage 1 and 2 assessments by identifying any major non-conformities that have not been addressed.

Step 3: Stage 1 audit

Review the results of the audit, including:

• General observations
• Non-conformities (major or minor, see below)

Minor non-conformities: These are not seen as serious. The organisation must complete an internal Corrective Action Plan (CAP) before Stage 2. CAP is not required to be sent to the Assessment Team at Stage 1.

Major non-conformities: These are more serious. The organisation will need to submit a CAP within ten days of receiving the audit report, with all actions scheduled to be completed before Stage 2. The CAP should be sent to the Assessment Team. The major non-conformities raised during Stage 1 will be re-assessed during Stage 2 Audit.

Step 4: Stage 2 audit

This is an on-site audit and takes place after the organisation has successfully completed Stage 1 and corrected any major non-conformities identified during the Stage 1 audit. Stage 2 confirms that the organisation’s management system is fully aligned to the standard. The evaluation is of management system implementation and its effectiveness.

Outcome: The audit report will detail the following:

• Any positive observations
• Opportunities for improvement – suggestions for improvement and any findings that could lead to potential non-conformities.
• Non-conformities (Major or Minor)
• Recommendation for Certification

Minor non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit this to the Assessment Team within 45 working days of receiving the audit report. The Assessment Team will review the CAP; it must detail the non-conformity, the cause, the proposed corrective action, who is responsible and the date the action will be implemented. Based on the evaluation of CAP, the recommendation for certification will be made.

For minor non-conformities, if an organisation has a corrective action procedure, this will not delay the certificate.

Major non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit it within 90 days (or 180 days depending on the number and risk of major non-conformities) of receiving the audit report be sent to the auditor.

What Comes Next?

Stay tuned for the second instalment in our two-part series about the ISO 37001:2016 certification process: sign up for our newsletter HERE!

In 2016, CRI Group™ launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body that provides education and certification services for individuals and organisations on a wide range of disciplines and ISO standards, including ISO 31000:2018 Risk Management- Guidelines, ISO 37000:2021 Governance of Organisations, ISO 37002:2021 Whistleblowing Management System, ISO 37301:2021 (formerly ISO 19600) Compliance Management system, Anti-Money Laundering (AML) and ISO 37001:2016 Anti-Bribery Management Systems. 

Who is CRI Group™?

Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

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Meet Samia El Kadiri; Gifted Consultant, Author & Trainer

CRI Group™ is delighted to welcome Samia El Kadiri as an Auditor at our sister brand the Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence. Samia provides audit services and expertise on existing compliance and Anti-bribery Anti-corruption management systems to assess effectiveness and vulnerabilities while ensuring compliance with Internal Standards, FCPA rules, UK Bribery Act laws, Anti-Money Laundering regulations, and all other global, regional and local regulations. For this reason, we are also delighted to announce that Ms El Kadiri will be a guest speaker on our upcoming webinar with our sister brand ABAC® titled “Building a Culture of Compliance and Trust Through ISO 37301:2021 Compliance Management Systems”.

MORE ON THE WEBINAR HERE

Widespread trust is built on a company culture of doing the right thing, where every employee contributes because they understand and believe in its importance. Don’t miss out!

Meet Samia

Samia El Kadiri Consultant , Author & Trainer 6σGB |IRCA- QMS Lead Auditor | TOT Auditor | Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence

She brings in over eight years of progressive experience working in private and government owned entities in compliance, management, quality assurance and excellence functions. Possess keen understanding, oversight and reporting mechanisms on Financial Crimes – Anti-Money Laundering, UAE Central Bank regulations, Dubai and UAE federal government mandates. She Developed and delivered various number of workshops and awareness sessions to leaders and decision makers on “Good Corporate Governance Practices”, “Development of Strategic Plan and Effective Policies” and “Financial Ethics” (AML&CFT according to local Guidelines). She authored reports and research papers on Compliance and the evolution of CG in the MENA region.

She participated in the ESG Index; MENA wide Environment, Social and Governance (ESG) Index in cooperation with Standard & Poor’s with the support of the International Finance Corporation (IFC).

She is a Consultant at DIFC – Hawkamah Institute for Corporate Governance charged with leading entities consultancy and advisory engagements in identifying the relevant controls, processes and frameworks and recommend areas of improvements. She works closely with clients in assessment and development, advisory and succession planning across multiple industries (Dubai and Federal Government entities, Healthcare, Financial institutions including Banks, and Real Estate) and functional topics (Ethics, Strategic excellence, ESG, Clinical Governance, Regulatory Compliance, Audit & Risk , Policies & Procedures…etc.).

Prior to joining Hawkamah she was the Regulatory Compliance Officer and Chief Editor of Compliance newsletter at Wall Street Exchange, a member of Emirates Post Group where she developed systems, policies and procedures for compliance of relevant UAE laws. Prior to that she worked with the American Clinics for Psychiatry and Neurology where she focused on health care compliance of Dubai Healthcare Authority’s mandates. Prior to ACPN she worked at Roads and Transport Authority (RTA) in Dubai where she focused on government excellence, quality management, and customer happiness.

She is Graduated with a BSC in Economics. She is a Certified Train the Trainer – Institute of Leadership and Management (UK), In addition to other accreditations related to Anti-Money Laundry (AML) and Counter Financing Crimes. She is fluent in English, Arabic and French.

WATCH SAMIA AT OUR UPCOMING WEBINAR

Samia is our guest speaker at our upcoming WEBINAR “Building a Culture of Compliance and Trust – an essential part of a corporate compliance program”. Our intention with this free webinar is to be able to provide resources on corporate compliance to organisations around the globe that will aid them in expansion and an ethical working environment. Widespread trust is built on the corporate culture and understanding of making the morally correct decision and we want to aid organisations to reach a degree to which every employee contributes towards this because they understand and believe in its importance. Our “Building a Culture of Compliance and Trust Through ISO 37301:2021 CMS” webinar will highlight all essential parts of a corporate compliance program.

SAVE YOUR SEAT NOW!

Our webinars, resources and other events are always designed with our clients in mind. Expect to be provided detailed insights and expert opinions to all of your questions and queries in regards to compliance adequate due diligence for third-party risk management, corporate compliance program and what it means for your organisation.

Check out some of Samia’s publications:

• “HOW SHOULD BOARD MEMBERS OVERSEE CRISIS COMMUNICATIONS” – Thought leadership piece published on April 2020 with a comprehensive review of GCC Corporate Governance regulations on crisis communication.
• “CORPORATE GOVERNANCE AND DATA PROTECTION DEVELOPMENTS ACROSS THE GCC” – A study report in partnership with a leading Corporate Governance software provider company, it provides an overview of recent developments in corporate governance and data protection landscape in the MENA region.
• UAE Business Magazine, Article “The Benefits of Good Governance in Times of Crisis”
• “COMPLIANCE FUNCTION; Reporting lines and Effectiveness” – Survey report about the role of Compliance function in the MENA region- July 2021

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Risk Assessment Breakdown: Identification, Analysis, and Evaluation

Risk management is a full-time, ongoing endeavour for organisations in today’s business world, and it poses constant challenges. Unfortunately, fraud, bribery and corruption are major factors affecting businesses and agencies of all sizes and industries. Being proactive against these risks can mean the difference between success and ruin. Whatever your reasons or motivations might be, if your organisation’s objective is to have an effective risk assessment management strategy in place. This article discusses the importance of Risk Assessment. There are two important building blocks that form the core of risk management:

• Risk assessment
• Risk treatment

Each of these stages can stand on their own – in this article we will go into detail about best practices for identifying risks, how to analyse them in terms of probability and severity, and how they can be evaluated in terms of the company’s risk appetite.

What is Risk Assessment?

Risk assessment is the overall process of identification, analysis and evaluation of any given risk. It can be a systematic examination of a task, job or process that a risk professional carries out at work for the purpose of identifying significant hazards. For example, the risk of someone being harmed and deciding what further control measures to take to reduce the risk to an acceptable level. The process will vary between organisations, but it should start with identification of hazards, analysis of who and what might be harmed, evaluation of the risk, documentation of the risks, taking action and review. Your organisation should conduct a risk assessment systematically, interactively and collaboratively, drawing on the knowledge and views of stakeholders. It should use the best available information, supplemented by a further inquiry as necessary.

Risk assessment breaks down into:

• Step 1: Identification
• Step 2: Analysis
• Step 3: Evaluation

Business Intelligence (BI) Solutions can help during this stage. BI take many shapes and forms in today’s complex business environment. Budgets are stretched and the challenges facing a business and its employees can sometimes lead to issues that start off small, but then lead to wider spread problems which can affect the very fabric of your organisation and damage both your credibility, reputation and bottom line profits. CRI Group™ takes two approaches to BI solutions:

• Intelligence operations (via market research and analysis): we focus on researching the future and potential growth of your business – i.e. determine the commercial viability and potential for success in the market, analyse consumer behaviour and business trends in that market, etc.
• Investigative operations (via commercial investigations): we focus on the current status of your business – i.e. location of assets, financial information, identification of unmet needs of any market, gauge brand awareness and identity in the market, etc.)

CHECK OUT OUR BI SOLUTIONS  or  DOWNLOAD BROCHURE

Risk Identification

The purpose of risk identification is to find, recognise and describe risks that might help or prevent an organisation achieving its objectives. Relevant, appropriate and up-to-date information is important in identifying risks. The organisation can use a range of techniques for identifying uncertainties that may affect one or more objectives. The following factors, and the relationship between these factors, should be considered:

• Tangible and intangible sources of risk;
• Causes and events;
• Threats and opportunities;
• Vulnerabilities and capabilities;
• Changes in the external and internal context;
• Indicators of emerging risks;
• The nature and value of assets and resources;
• Consequences and their impact on objectives;
• Limitations of knowledge and reliability of information;
• Time-related factors;
• Biases, assumptions and beliefs of those involved.

Your organisation should identify risks, whether or not your sources are under your control. Consideration should be given that there may be more than one type of outcome, which may result in a variety of tangible or intangible consequences.

Risk Analysis

Risk analysis allows you to understand the nature of risk, its characteristics and level. Because an event can have multiple causes and consequences and can affect multiple objectives a risk analysis should involve a detailed consideration of uncertainties such as risk sources, consequences, likelihood, events, scenarios, controls and their effectiveness.

Risk analysis can be undertaken with varying degrees of detail and complexity, depending on the purpose of the analysis, the availability and reliability of the information, and the resources available. Analysis techniques can be qualitative, quantitative or a combination of both, depending on the circumstances and intended use. Risk analysis should consider factors such as:

• The likelihood of events and consequences;
• The nature and magnitude of consequences;
• Complexity and connectivity;
• Time-related factors and volatility;
• The effectiveness of existing controls;
• Sensitivity and confidence levels.

A risk analysis is likely to be influenced by a wide range of variables, from any divergence of opinions, biases to perceptions of risk, from judgements, quality of the information used to the assumptions and exclusions made and any limitations of the techniques and how they are executed. These influences should be considered any risk analysis, documented and communicated to any decision-makers involved in the process.

It is important to remember that any highly uncertain event can be difficult to quantify, and this is an issue. If you find yourself in such a situation, using a combination of techniques generally provides greater insight. Risk analysis provides input to risk evaluation, to decisions on whether risk needs to be treated and how, and on the most appropriate risk treatment strategy and methods. The results provide insight for decisions, where choices are being made, and the options involve different types and levels of risk.

Risk Evaluation

Risk evaluation can support your decisions. Risk evaluation involves comparing the results of the risk analysis with the established risk criteria to determine where additional action is required. This can lead to a decision to:

• Do nothing further;
• Consider risk treatment options;
• Undertake further analysis to better understand the risk;
• Maintain existing controls;
• Reconsider objectives.

Any decisions should take into account the wider context and the actual and perceived consequences to external and internal stakeholders. The outcome of risk evaluation should be recorded, communicated and then validated at appropriate levels of the organisation.

Who should do Risk Assessments?

Well, by law, every employer must conduct risk assessments. Risk assessments should always be carried out by a professional who is familiar to risk, a person who is experienced and competent to do so.  Competence can be expressed as a combination of knowledge, awareness, training, and experience. Remember competence does not mean you have to know everything about everything, competence also means knowing when you know enough or when you should call in further expert help.

But we all like to think that all of our employees will be trustworthy, but this is not always the case. There have been many instances in which an employee has been dishonest about their job history, qualifications or even criminal history. A dishonest employee could be unqualified for the position, possibly endangering others on the job. Or they might be a fraud risk, willing to bend the truth in other ways in order to enrich or advance themselves on your dime. No organisation can afford to have employees or staff who aren’t what they claim to be. Even a seemingly innocent embellishment can indicate more background problems under the surface, and the potential for future problems down the road so remember, trust your employees but, verify them too. 

CHECK OUT OUR EMPLOYEE BACKGROUND SCREENING SOLUTIONS  or  DOWNLOAD BROCHURE

Risk Assessment and ISO 31000 Certification with ABAC™

While the team at CRI® do not deliver any training or certification on ISO 31000, our partner ABAC™ Center of Excellence do. ISO 31000 can provide the principles, framework and a process for managing risk. ISO 31000 is not a certifiable standard; the standard is a set of guidelines which provide guidance for internal or external audit programmes. However we recommend taking ISO 31000 Awareness training, this will enable you to fully understand Risk Management activities and mitigate risk. 

ISO 31000 was developed by hundreds of experts in risk mitigation, from thirty countries. This international effort produced a standard that is worldwide and represents best practices and leading operations for risk management. Organisations can trust that they are following a tested, robust standard to increase success. The standard converts risk management into a set of “friendly” and actionable – and straightforward to implement – guidelines, regardless of the size, nature, or location of a business. 

The training helps establish an ethical culture by educating your personnel on the following:

• What constitutes fraud, corruption, and bribery, and why these are so damaging to business
• How to identify red flags of fraud, corruption, and bribery
• The process for reporting fraudulent and unethical acts
• The organization’s zero-tolerance attitude toward unethical behaviour and willingness to terminate employees for breaches, and prosecute unethical acts
• The serious ramifications for committing fraud or bribery, the legal consequences, and the negative impact on one’s career

The ISO certifications helps us at ABAC™ to provide appropriate anti-bribery training to personnel across various industries. This standard helps to assess bribery risks, perform the appropriate due diligence required for your business and to take reasonable and proportionate steps to ensure that controlled organizations and business associates have implemented appropriate anti-bribery controls.

> Find out more about ISO 31000 Risk Management and other standards now!

Other Solutions

While CRI™ may not offer the ISO certification, we do offer other services. We specialise in solutions regarding compliance, working as trusted partners to businesses and institutions across the globe. Our experts work with energy, insight and care to ensure we provide a positive experience to everyone involved – clients, reference providers and candidates. CRI’s unique identity and vision evolved from our fundamental desire to support our clients and their candidates, thus creating the DueDiligence360™.

The DueDiligence360^TM reports to help organisations comply with anti-money laundering, anti-bribery, and anti-corruption regulations. This service also proves beneficial ahead of a merger, acquisition, or joint venture as it can be used for a third-party risk assessment, onboarding decision-making, and identifying beneficial ownership structures. Identifying key risk issues clearly and concisely helps enhance your knowledge and understanding of the customer, supplier, and third-party risk, helping you avoid those involved with financial crime.

Why not consider our background investigative solutions? Employee Background Checks can aid in reducing the risk of hiring an employee who does not live up to their supposed skill set and could cause irrevocable damage. Firms spend years, thousands, even millions to brand their products and services – it only takes one bad hire to cause loss of capital and reputation. It can go as far as bringing a business to fail – especially if the employee holds malice towards the organisation. EmploySmart™ is CRI’s own solution aiming to expose vulnerabilities and threats within your organisation. Much like the ISO certification, our EmploySmart™ is a risk management measure which can be used to significantly reduce business and financial crime, fraud and malpractice within your workplace.

Our solutions are also certified by the British Standard Institute BSI for the scope of BS 7858:2019 Screening of individuals working in a secure environment, Code of practice (the only BS 7858 certified background screening services provider in the UAE and across the Middle East); and BS 102000:2018 Code of practice for the provision of investigative services.

Another risk management solution to consider from CRI® is our Third-Party Risk Management solution (TPRM),  also known as 3PRM™. In wake of the global pandemic, the 3PRM™ was developed in a bid to aid organisations to accurately determine the legal compliance, financial viability, and integrity levels of external parties, vendors, and customers who seek to be affiliated with and represent the business.

The 3PRM-Certified™ program consists of gap analysis and investigative due diligence on the targeted above parties.  This highly thorough program reveals anti-corruption, compliance and risk management discrepancies associated with the international regulatory framework helping your business to flourish at any scale. Find out more about CRI Group’s Solutions here.

If you’re unsure of what solution may be best for you and your business, how about connecting with one of our experts for a free consultation? Receive tailored advice from the top analysts and investigators across the globe.

CONTACT US

About CRI Group™

Based in London, CRI™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI™ launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC™ operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC™ for more on ISO Certification and training.

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WEBINAR | Breaking Down The ISO 37001 Audit Process

CRI Group’s ABAC™ will be hosting a paid webinar on the 30th of September exploring the Pitfalls Most Organisations Often Commit – the importance of implementing Anti-Bribery Management System (ABMS). Being a part of the solution means being able to share our expert knowledge on what would be best for your organisation.

Registration Expired

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Why Financial Services Firms Need ISO 37001 ABMS?

When Société Générale, a global financial services institution based in France, agreed to pay a combined total penalty of more than $860 million for an alleged bribery and corruption scheme, it served as a warning shot to financial firms worldwide that a culture of enforcement has arrived. Société Générale was accused of paying bribes to officials in Libya and committing violations in manipulating the London InterBank Offered Rate (LIBOR), one of the world’s leading benchmark interest rates. Together with other regulatory penalties faced by the financial services giant, the total amount to be paid exceeds $1 billion. (The United States Department of Justice, 2018)

Bribery and corruption often go together with money laundering – and, as such, the financial sector faces new Anti-Money Laundering (AML) rules and legislation that is strict and increasingly enforced. Remaining in compliance through implementing proper prevention controls is a must. Failing to do so can mean a loss of business, trust and reputation: Banking giant Citibank was fined $70 million in the US for failing to address shortcomings in its anti-money laundering policies. We at CRI intend on being apart of the solution. Therefore, CRI Group’s ABAC™ will be hosting a webinar on the 30th of September exploring the Pitfalls Most Organisations Often Commit – the importance of implementing Anti-Bribery Management System (ABMS). Being a part of the solution means sharing our knowledge so society is one step closer to an ethical reality.

Registration Expired

In the US alone, more than 100 bribery investigations were in progress at the end of last year, with the financial services industry facing the most investigations. (Wall Street Journal, 2019)

Having layers of safeguards in place is required both from a legal and compliance standpoint. One of the most critical layers is an effective anti-bribery management system (ABMS).

Prevent Corruption and Promote Compliance

There is a solution that financial services organisations can implement to take a proactive stance against bribery and corruption: The ISO 37001:2016 Anti-Bribery Management System standard. ISO 37001 ABMS is designed to help global organisations implement an anti-bribery management system (ABMS), as the standard specifies a series of measures required by the organisation to prevent, detect and address bribery, and provides guidance relative to that implementation.

For financial services firms, this is a critical layer of protection that provides both anti-bribery controls and a system for compliance with various anti-corruption legislation, such as the FCPA and UK Bribery Act. The UK Bribery Act’s adequate procedures requirement dictates that all companies need to have ongoing monitoring, training, surveillance and risk assessments – ISO 37001 ABMS is designed to fulfil these criteria and more.

CRI Group’s ABAC™ Certification Services is accredited to offer independent ISO 37001 certification to ensure that an organisation is in compliance with the standard, which is recognised and practised in more than 160 countries worldwide. CRI Group’s auditors and analysts work with financial services organisations to develop measures that integrate with existing management processes and controls, and include:

• Adopting an anti-bribery policy
• Establishing buy-in and leadership from management
• Training personnel in charge of overseeing compliance
• Communicating the policy and program to all personnel and business associates
• Providing bribery and corruption risk assessments
• Conducting due diligence on projects, business associates and other third-party affiliations
• Implementing financial and commercial controls
• Developing reporting and investigation procedures

Our paid webinar will have a rundown of the following:

• What are the core Bribery and Corruption Risks for Financial Institution?
• How to protect financial institutions and corporations from bribery and corruption risk
• Reparations from bribery that could affect the businesses, clients, and employees
• Successful regulations to mitigate risk for bribery and corruption.
• What can be done if bribery is detected?
• Internationally recognised solutions laid forth by ISO 37001: Anti-Bribery Management System that gives businesses effective controls to mitigate risk
• Components of risk management at a financial institution

We will also be exploring how the implementation of such a standard aids in examining and dealing fittingly with any actual or suspected bribery within the corporation and also how to implement appropriate financial, procurement and other commercial controls so as to help prevent the risk of bribery in financial services as these organisations face unique challenges.

Register Here (Expired)

Among them are maintaining proper internal procedures as they relate to bribery and AML regulations. These measures can be logistically challenging, especially in the auditing process – but keeping accurate books and records is a key provision of the UK Bribery Act. ISO 37001 ABMS standard makes this a key provision in cultivating proper due diligence and reporting procedures.

Another major challenge involves monitoring third-party risk. The due diligence practices and risk assessments implemented through ISO 37001 ABMS are critical in this area. Financial services firms, more than any other sector, must conduct effective vetting and ongoing monitoring of third-parties. This goes beyond “on-boarding” and relates to how companies continually assess risk from outside partners – including brokerage firms, introducers, agents, joint-venture relationships, even clients – as borrowers, for example, represent a major risk on the balance sheet.

Some financial services companies do not properly score or assign risk profiles to third-party partners, and this can represent a major weak point in efforts to prevent bribery, corruption and money laundering. Regulators understand this, too. That’s why ISO 37001 ABMS dictates thorough and comprehensive due diligence in regards to all third-parties and especially in the case of mergers and acquisitions.

Once certified, an organisation must continue surveillance and undergo a recertification audit over three years to ensure that the organisation still complies with the ISO 37001:2016 ABMS standard. During this time, any changes to processes, the addition of new partners and expansion/acquisition of new assets or energy contracts, etc. are carefully reviewed.

Long-lasting Benefits of Certification

ISO 37001 ABMS provides a strong framework for addressing and isolating risk factors, and the benefits of certification are far-reaching, impacting not just the primary organisation but also influencing contractors, clients, and raising the profile of the company as an ethical entity that is a good trading partner. By achieving ISO 37001:2016 ABMS certification, a financial services firm will:

• Ensure that the organisation is implementing a viable anti-bribery management system utilising widely accepted controls and systems.
• Assure management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption.
• If needed, provide acceptable evidence to prosecutors or courts that the organisation has taken reasonable steps to prevent bribery and corruption.

Cases like Société Générale are not isolated, but more and more, we are seeing companies punished for not taking proper preventative action with a robust anti-bribery management system (ABMS). Financial services firms need to be aware and stay in front of increased anti-bribery and corruption legislation given that such regulations have, in most cases, achieved a global reach. For ownership and management, the stakes are especially high – accountability now includes criminal liability for organisation personnel as individuals, beyond (and in addition to) liabilities faced by the organisation. This trend will only continue as governments, and their publics become increasingly intolerant of fraud, bribery and corruption. Significant media coverage and the real and perceived threat to governments’ economies contribute to this changing landscape of public opinion.

As the ISO 37001 International standard document states, “Conformity with (ISO 37001) cannot provide assurance that no bribery has occurred or will occur in relation to the organisation, as it is not possible to eliminate the risk of bribery. However, (the standard) can help the organisation implement reasonable and proportionate measures designed to prevent, detect and respond to bribery”. With this in mind, It’s important to note that ISO 37001 certification, on its own, is not a “safe harbour” from prosecution should bribery or corruption be discovered. Significantly, ISO certification is, as the above explains, a potential mitigating piece of evidence to regulators or even prosecutors and the courts that the entity has taken meaningful steps in its efforts to prevent bribery and corruption.

Financial Services Firms Need ISO 37001 ABMS

It is critical that any financial services organisation have a proper, comprehensive strategy to prevent and detect bribery and corruption, and remain in compliance with all regulations – on the local, regional, and international levels. The ISO 37001 ABMS standard is an established, tried and tested program to address those issues head-on through a comprehensive program of training and certification. The training process is tailored to the organisation while still following the developed curriculum and documented best practices. Due diligence procedures and risk assessments are applied in a thorough, comprehensive manner. Certification requires the demonstration that processes have been implemented effectively, with follow-up evaluations.

Worldwide developments in laws and regulations have demonstrated that there isn’t time to wait to implement controls and compliance procedures – the next investigation and/or prosecution may be too late. The harm caused by bribery and corruption to an entity’s reputation, investments and business can be far-reaching and long-lasting.

This paid webinar will be running from the following times on Thursday the 30th of September;

• 08:00 to 10:00 GMT
• 15:00 to 17:00 MYT
• 12:00 to 14:00 GST

Your turnout with come with a certificate of Attendance (COA) as well as a complimentary webinar ABMS Awareness for 2 Pax per company. While you’re there, why not attain a Continuing Professional Development (CPD) certificate and stay on top of your industry?

Register your place for this webinar here and find out how to tackle the issue of bribery and corruption in your workplace before it has time to manifest itself into a greater issue. Finance is the greatest asset to the economy after all.

Complete Registration (Expired)

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ISO 37001 Solutions for All Industries (Part 3)

In part 1, we discussed how ISO 37001 ABMS can help companies across a wide range of industries, including automotive, aviation and insurance. In part 2, we looked at how pharma and healthcare, property, IT and telecommunications organisations can benefit from Anti-Bribery solutions as well. In this final part, we will explore some aspects of how companies from the financial, oil and energy industries could implement ABAC solutions.

Finance

Bribery and corruption are among the top fraud concerns for all financial organisations. These include banks & financial institutions, real estate lenders, business credit and finance companies, commercial investment corporations, asset-based lenders, debt financing firms, acquisition capital firms and others. Having safeguarding processes in place is required both from a legal and compliance standpoint and from the position of being a trusted, secure financial institution. The financial sector includes new Anti-Money Laundering (AML) rules and legislation, and these regulations are strict and increasingly enforced. As such, remaining in compliance through implementing proper prevention controls is a must.

In one high-profile case, between 2006 and 2013, JPMorgan Chase and its subsidiary, JP Morgan Securities (Asia Pacific) Limited (JPM-APAC) took on about 100 Chinese interns and full-time employees who ended up at the centre of a bribery case spread over two continents and worth hundreds of millions of dollars. In order to win business from members of the Chinese government and state-owned companies, JPM-APAC allegedly targeted their children, offering them high-ranking and well-paid positions in the business in order to curry favour with their parents. JP Morgan fell into trouble for allegedly violating the Foreign Corrupt Practices Act (FCPA), and the DoJ called the scheme ‘bribery by any other name’ – alleging that it had threatened national security. In November 2016, the bank was ordered to pay $264 million to settle the claims against it – $130m to the SEC for violations of the FCPA, $72m to the US Justice Department and $61.9m to the Federal Reserve Board of Governors.

CRI Group™ investigates: Pharma corruption case included CFO

ISO 37001 in Oil, Gas and Energy Industries

The oil and energy sector is a massive portion of the world’s economy, dealing mainly in petroleum – including upstream (exploration, development and production of crude oil or natural gas) and downstream (oil tankers, refiners, retailers and consumers) pipeline. The need to prospect, discover, and realise oil and energy production in various (and often far-flung) locations lends to the vulnerability to fraud – but geographic considerations aren’t the only risk factors.  Perhaps even more impactful is the complexity of business relationships required to operate in the industry – relationships with governments, contractors, regulators, investors/venture partners, equipment suppliers and other parties. Every such interaction and dealing can be considered susceptible to bribery and corruption where cutting corners may be considered profitable or even perceived to be “business as usual.”

An infamous example is the case of Petrobras. In December 2017, the world’s largest builder of offshore rigs agreed to pay $422 million in penalties after entering a guilty plea for bribery charges connected with the Petroleo Brasileiro (Petrobras) scandal. Keppel Offshore & Marine Ltd. made illicit payments to both Petrobras officials and government representatives for more than a decade, between 2001 and 2014 (Reuters, 2017). The sweeping multimillion-dollar bribery scandal that rocked Petrobras led to numerous investor lawsuits and the downfall of disgraced government officials. It also served as the embodiment of the huge risk of bribery and corruption that confronts the entire oil and energy sector. See “Oil and Energy Companies Look to ISO 37001.”

Long-lasting Benefits of Certification of ISO 37001

ISO 37001 provides a strong framework for addressing and isolating risk factors in all industries. The benefits of certification are far-reaching, impacting not just the primary organisation but also influencing contractors, clients, and raising the profile of the company as an ethical entity that is a good trading partner. Even more effective, ABAC™ tailors IS0 37001 to the specific needs of the client.

By achieving ISO 37001:2016 certification, an organisation will ensure that it is implementing a viable anti-bribery management system utilising widely accepted controls and systems. It will also assure management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. Today, companies cannot afford to be reactive to threats of bribery and corruption. By achieving ISO 37001 Anti-Bribery Management System certification today, an organisation will remain in compliance and better positioned to address risks head-on.

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Who is CRI Group?

Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

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Mubadala Petroleum Achieved ISO 37001 ABMS Certification Through CRI Group™

Corporate Research and Investigations Limited (CRI Group™) announced that Mubadala Petroleum, a leading international oil and gas company, has successfully achieved ISO 37001 Anti-Bribery Management Systems certification.

The announcement was made by Zafar Anjum, CEO at Corporate Research and Investigations Limited. “We are honoured to certify Mubadala Petroleum for ISO 37001, as the ethical and transparent front-runner in the oil and gas industry.”

Mubadala Petroleum is a leading international, upstream oil and gas exploration and production company that manages assets and operations spanning ten countries globally, with a primary geographic focus on the Middle East and North Africa, Russia and Southeast Asia.

The ISO 37001 certification was achieved through ABAC™ Certification, a component of CRI Group’s Anti Bribery and Anti-Corruption (ABAC™) Center of Excellence, accredited by the Emirates International Accreditation Center (EIAC) for administering ISO 37001 ABMS certification.

ABAC’s Scheme Manager, Huma Khalid added: “Mubadala Petroleum was very motivated to achieve the globally recognised certification to prove their commitment to the highest integrity and accountability levels across the world. It is an honour to certify Mubadala Petroleum in the UAE in numerous business areas including but not limited to ABC ethics & compliance, ABC risk assessment and management, business management, investigations and reporting, due diligence and employment procedures. It is encouraging that exponential number of worldwide organisations start deciding to not only commit to their sustainable business commitments but also achieve certification to promote transparency inside and outside their organisations.”

ABOUT CRI GROUP™

Since 1990, CRI Group™ (Corporate Research and Investigations Limited) has safeguarded businesses from fraud and corruption, providing insurance fraud investigations, employee background screening, investigative due diligence, third-party risk management, compliance and other professional investigative research services.

CRI Group’s ABAC™ Center of Excellence provides certification and training solutions to local organisations in the field of Anti-Bribery Management Systems, Risk Management Systems, ISO 37301 Compliance Management Systems.

Stop Bribery and Corruption Today – With ISO 37001 Certification!

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What are the Stages of ISO 37001 Certification?

The ISO 37001:2016 Certification is an Anti-Bribery Management System Certification critical for organisations in the public, private and non-profit sectors. After all, consider the benefits: Certification adds a distinct level of credibility to the organisation’s management systems and ensures that the organisation implements a viable anti-bribery management program utilising widely accepted controls and systems. It assures management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. ISO 37001:2016 certification also protects the organisation, its assets, shareholders and directors from the effects of bribery. But what, exactly, is the process for getting ISO 37001:2016 certified by CRI Group? Once your organisation has submitted questionnaire information and completed the approval and contract stage, the certification cycle is ready to begin.

A Breakdown of the Stages of ISO 37001:2016 Certification

Step 1: Audit Confirmation

An audit plan will be developed with your organisation and confirmed to the Certification’s Body Assessment Team at least three months before the organisation’s first audit.

Step 2: Pre-assessment Audit (optional)

The organisation can opt to perform a pre-assessment audit to identify any possible gaps between its current management system and the standard requirements. This audit is optional and helps the organisation check its preparedness for the stage 1 and 2 assessments by identifying any major non-conformities that have not been addressed.

Step 3: Stage 1 Audit

Review the results of the audit, including:

• General observations
• Non-conformities (major or minor, see below)

Minor Non-conformities: 

These are not seen as serious. The organisation must complete an internal Corrective Action Plan (CAP) before Stage 2. CAP is not required to be sent to the Assessment Team at Stage 1.

Major Non-conformities: 

These are more serious. The organisation will need to submit a CAP within ten days of receiving the audit report, with all actions scheduled to be completed before Stage 2. The CAP should be sent to the Assessment Team. The major non-conformities raised during Stage 1 will be re-assessed during Stage 2 Audit.

Step 4: Stage 2 Audit

This is an on-site audit and takes place after the organisation has successfully completed Stage 1 and corrected any major non-conformities identified during the Stage 1 audit. Stage 2 confirms that the organisation’s management system is fully aligned to the standard. The evaluation is of management system implementation and its effectiveness.

Outcome: The audit report will detail the following:

• Any positive observations
• Opportunities for improvement – suggestions for improvement and any findings that could lead to potential non-conformities.
• Non-conformities (Major or Minor)
• Recommendation for Certification

Minor non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit this to the Assessment Team within 45 working days of receiving the audit report. The Assessment Team will review the CAP; it must detail the non-conformity, the cause, the proposed corrective action, who is responsible and the date the action will be implemented. Based on the evaluation of CAP, the recommendation for certification will be made.

For minor non-conformities, if an organisation has a corrective action procedure, this will not delay the certificate.

Major non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit it within 90 days (or 180 days depending on the number and risk of major non-conformities) of receiving the audit report be sent to the auditor.

What Comes Next?

Stay tuned for more on ISO 37001:2016: sign up for our newsletter HERE! ISO 37001:2016 Anti-Bribery Management System certification is offered under CRI Group’s ABAC™ Centre of Excellence, an independent certification body established for Anti-Bribery Management System training and certification, ISO 37301 Compliance Management Systems and Risk Management System certification. The program will be tailored to your organisation’s needs and requirements. For assistance in developing and implementing a fraud prevention strategy, contact ABAC™ today or get a FREE QUOTE now!

Who is CRI Group™?

Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

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Q&A: Corporate Fraud & Corruption in the UK 2021

The United Kingdom scores 77 out of 100 on Transparency International’s (TI)  2020 Corruption Perceptions Index (CPI), as is one of the 25 least corrupt countries across the globe. However, it all seems great on the surface as corporate fraud and corruption cases have been noticeable in various industries across the UK. TI reports that corrupt actors enjoy their illicit gains by “buying luxury property in the world’s most sought-after cities, like London”. Based on the article “CPI 2020: Trouble in the top 25 countries”, “While the UK (77) is the first G20 country to launch a public register of beneficial ownership, a loophole in the law allows foreign companies to purchase real estate anonymously. This is particularly problematic as research shows that over 75 per cent of properties subject to criminal investigations between 2004 and 2015 used offshore anonymous companies to hide their owners’ identities. The UK government committed to closing this loophole by introducing a register of beneficial ownership for property, but it has yet to be implemented. The necessary legislation has been subject to significant delays. In the meantime, rich businesspeople linked to autocratic regimes are allegedly purchasing property via shell companies, such as billionaire and daughter of former President of Angola, Isabel de Santos.”

To discuss the situation of corporate fraud and corruption, CRI Group™ and its ABAC™ Center of Excellence were invited to share the expert views in the special InDepth Feature by Financier Worldwide “Corporate fraud and corruption 2021”. In this edition, CRI Group’s CEO Zafar Anjum and ABAC®’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption. Read on the answers to the below questions:

• To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in your country of focus?
• Have there been any legal and regulatory changes implemented in your country of focus designed to combat fraud and corruption? What penalties do companies face for failure to comply?
• In your opinion, do regulators in your region have sufficient resources to enforce the law in this area? Are they making inroads?
• If a company finds itself subject to a government investigation or dawn raid, how should it respond?
• What role are whistleblowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?
• What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
• What general steps can companies take to proactively prevent corruption and fraud within their organisation?

Q: To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in your country of focus?

A: The COVID-19 pandemic has created increased opportunities for fraud worldwide. The UK is not immune, unfortunately, and such a disruptive event as the pandemic increases the likelihood that normal safeguards and risk management controls can be bypassed and subverted. There has been an increase in reported fraud and corruption cases over the past year. A survey of fraud experts by the Association of Certified Fraud Examiners (ACFE) in August 2020 showed that 77 percent were seeing an increase in fraud. Perhaps not surprisingly, cyber fraud is the fastest-growing problem area, but there has also been an uptick in unemployment fraud. This is bad news in the UK, where fraud is our most common crime, costing the country £190bn annually, according to the Royal United Services Institute (RUSI).

Q: Have there been any legal and regulatory changes implemented in your country of focus designed to combat fraud and corruption? What penalties do companies face for failure to comply?

 A: There is proposed legislation, supported by the secretary of state of the UK’s Department of Business, Energy and Industrial Strategy, that would increase accountability for corporations that produce falsified financial statements. This includes a provision that would require company directors to personally sign off on their corporation’s financial statements, under penalty of fines and possible prison time. Under the Sarbanes-Oxley Act in the US, the penalty for falsely certifying such statements is steep: up to 20 years in prison and up to $5m in fines, and the UK is looking at similar measures to step up its fight against fraud and corruption. The UK also recently approved the formation of an audit, reporting and governance authority (ARGA) that should come into force within the next two or three years. Accordingly, the UK is taking a stronger stance against fraud going forward.

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 Q: In your opinion, do regulators in your region have sufficient resources to enforce the law in this area? Are they making inroads?

A: Combatting fraud is never straightforward. When looking at progress in detecting and preventing fraud, it sometimes feels like a question of whether the glass is half full or half empty. For example, the Serious Fraud Office (SFO) brought 13 fraud defendants to trial in 2019 and 2020, with a 95 percent four-year success rate by case. Many of these represent large frauds, and they are meaningful wins, but how many more fraudsters are out there undiscovered? Other bodies, including Her Majesty’s Revenue and Customs (HMRC), among others, also have key roles to play in investigating fraud, but a considerable amount of fraud is still investigated and prosecuted at the local level. It is important for leaders in the UK to know what resources law enforcement have and where they need training and support in the fight against fraud.

Q: If a company finds itself subject to a government investigation or dawn raid, how should it respond?

A: Any investigation, and especially a raid, can be an incredibly stressful time for a company and its employees. The important thing is to not panic – the investigators have a job to do, and the sooner they get to the truth of the situation, the better for everyone. Companies should direct their management and their employees to cooperate fully, while also engaging legal counsel to properly protect the corporation from future litigation. If fraud is detected, it is a criminal matter and the company should make a good faith effort to work with prosecutors and regulators, while making sure to document all control measures and prior steps taken to manage fraud risk. Having a track record of meeting compliance requirements and having proper internal controls in place at the time fraud occurs could have a mitigating effect in terms of potential prosecution and penalties down the road. View the reprint of the interview, covering not only the UK but also the United Arab Emirates.

Q: What role are whistleblowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?

A: Employees are a company’s first line of defence against fraud and corruption. But training them to recognise the red flags of fraud is only half of the process. The company must also implement a reporting system that is anonymous and easy to use, so that employees are encouraged to report any suspicions. Then, the company must follow through and fully investigate any reports that do come in. If they do not, whistleblowers will believe that combatting fraud and corruption is not a corporate priority, and the tips will stop coming in. How important are those tips? According to the ACFE, they are by far the highest detection method for fraud, well above audits and other means. The company should communicate that a whistleblower hotline or online reporting system is available, and that there is a zero-tolerance policy for any type of retaliation against whistleblowers. Over time, the tips will come in.

Q: What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption? 

A: Investigations can be challenging, and they require expertise. For example, there are rules for collecting and handling evidence, including physical evidence and witness statements, that must be followed for such evidence to be admissible in court. There are also laws in the UK dealing with privacy and the rights of the accused. The bottom line is that a company already dealing with a potentially costly and damaging fraud scenario should not risk adding more legal trouble through a faulty investigation. Hire experts who deal with corporate crime and specialise in fraud and corruption cases. Like any other area of expertise, they will have the knowledge and resources to help proceed with an investigation and lead it to the most favourable outcome for your company. If you already have anti-fraud professionals on staff, let them take the lead, but provide outside resources as needed.

Q: What general steps can companies take to proactively prevent corruption and fraud within their organisation? 

A: A fraud prevention strategy has many different elements, and the sooner companies implement them, the sooner they can begin to work together in a proactive way to prevent fraud. Mandating employee training, such as ISO 37001 ABMS, having an ethical code of conduct signed by every member of staff, providing regular and surprise audits, and implementing a fraud reporting system are all effective ways to help prevent and detect fraud and corruption. None of these methods is strong enough on its own to properly protect organisations. But together, they can be very effective. It is also important to set a ‘tone at the top’, from ownership, directors and management on down, that fraud will not be tolerated. Anti-fraud controls only work if the company sees them through and thoroughly investigates every report. When fraud is confirmed, any perpetrators should be terminated and potentially prosecuted, sending a message of zero-tolerance.

Find out more about the ISO 37001 training

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI Group™ Chief Executive Officer
37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom
t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

Source & Credits

The original version of the Q&A was published on Financier Worldwide’s InDepth Feature: Corporate Fraud & Corruption 2021. Download the reprint here.

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CPI 2020 Overview: Middle East & Asia

The newly published Transparency International’s Corruption Perception Index (CPI 2020) has ranked 180 countries and territories by their perceived levels of public sector corruption. This index uses a scale of 0 to 100, where 0 is highly corrupt and 100 is very clean. CPI 2020 identified that despite progress, most countries still struggle to stop corruption effectively – more than 2/3 of countries score below 50 on CPI, with an average score of just 43. That proves the need to implement more stringent anti-bribery anti-corruption measures worldwide.

In this article, which was originally published on ABAC™ Center’s of Excellence website, we will look at how the Asia Pacific, the Middle East and Pakistan scored in the CPI 2020 and discuss solutions to tackle bribery in these regions.

Asia Pacific

Transparency International identified that with an average score of 45, the Asia Pacific region is still struggling to combat corruption despite continuous efforts. Region’s top leader New Zealand (88) is followed by Singapore (85), Australia (77) and Hong Kong (77). Conversely, Cambodia (21), Afghanistan (19) and North Korea (18) ranked lowest in the region. Malaysia, the country which introduced more stringent measures to fight bribery and corruption, proves that it takes time to see improvements. The country has moved down to 51 points compared to 53 points in 2019. Accordingly, the ranking also moved down to 57 in comparison with 51 in 2019. “Although a drop in the score appears statistically insignificant, the government must be cognizant that our rank falling 6 steps means that compared to other countries we are not improving as well as other countries in our efforts to fight corruption” – said Transparency International Malaysia in a statement. TI-M added: “The Government after coming into power in early 2020 committed to continue with the agenda to fight corruption and among them were to gazette the enforcement date of 1 June 2020 for the Corporate Liability and continue with the National Anti-Corruption Plan (NACP) initiated by the previous Government which is commendable. The NACP (National Anti-Corruption Plan) is a comprehensive plan but the government must ensure the implementation is effective and the Chief Secretary to the government should be empowered to lead the implementation and be made accountable”.

In our published whitepaper “South Asia grapples with anti-bribery compliance”, which overviews anti-bribery, anti-corruption and ISO 37001 solutions in Malaysia and entire in South Asia, we wrote that South Asia has a troubled record when it comes to preventing bribery and corruption, as well as enforcing compliance. Recent cases and statistics show that the problem persists in most countries in the region. Both government officials and private sector business leaders are struggling to adopt policies, control methods and best practices to help reduce bribery and corruption on their watch. High profile cases such as the 1MDB scandal in Malaysia and, more recently, the alleged Meikarta township case in Indonesia underscore this point. The investigations that were triggered by these cases demonstrate, however, that regulators are serious about addressing the threat of bribery and corruption as more than just a legal issue, but as a societal one, as well. In response, organizations that are committed to being in compliance are adopting the ISO 37001 – Anti-Bribery Management Systems standard as a comprehensive approach to mitigating risk and demonstrating ‘adequate procedures’ taken to prevent bribery and corruption.”

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Middle East

Transparency International identified that with an average score of 39, the Middle East and North Africa region is still perceived as highly corrupt, with little progress made towards controlling corruption. Even though the United Arab Emirates (71) and Qatar (63) are best performing in the region, UAE is still appearing in headlines with bribery and corruption scandals.

In the article “CPI 2020: Trouble in the top 25 countries” Transparency.org wrote: “The United Arab Emirates has been heavily criticised by the Financial Action Task Force (FATF) for its inadequate anti-money laundering framework. The country’s chaotic approach to registering companies makes it incredibly difficult for law enforcement to detect who is behind a suspicious company when thirty-nine different registries operate across the seven Emirates.

The UAE’s booming construction and real estate sector accounts for a fifth of the Emirates’ GDP, but remains vulnerable to money laundering because of complex and opaque ownership structures”.

Recently CRI® Group was featured in Financier Worldwide’s InDepth Feature: Anti-Money Laundering 2021 publication and shared the view about the unfortunate situation of money laundering in this region: “When it comes to money laundering, a recent report from Carnegie Endowment found that there is a steady stream of illicit funds from corruption and crime flowing into the UAE. This should be alarming to organisations and regulators alike. The perpetrators take advantage of ‘free trade zones’ and often the money is funnelled through real estate deals, especially in luxurious properties in Dubai, for instance. This might be facilitated by foreign mobsters, gold smugglers, and even warlords. These are high-level criminal operations that can pose a risk to any legitimate organisation operating in the UAE and the Middle East as a whole”. In this edition, CRI® Group’s CEO Zafar Anjum and ABAC®’s Scheme Manager Huma Khalid talked about the Anti-Money Laundering solutions and financial crime impact on businesses not only in UAE but across the globe: “Money laundering still represents a gap in enforcement, and organisations should not wait for government action to put their own AML frameworks in place. Like many countries around the world, the UAE is experiencing an uptick of fraud and financial crimes during the COVID-19 pandemic”. Read the full interview here.

Pakistan

As published in the press release, Pakistan’s CPI 2020 score “has lowered to 31/100 from 32/100 in 2019 and rank to 124/180 from 120/180 in 2019. This is despite NAB’s extraordinary efforts who claims to have recovered Rs363 billion in the last two years, and Public Accounts Committee claims to have recovered Rs. 300 billion over the previous two years”.

TI Pakistan recently reported that “A total of 95 corrupt persons were convicted and fined worth billion of rupees by various accountability courts during the last three years due to the vigorous persuasion of National Accountability Bureau, Rawalpindi“. The comment was made by the Director General NAB, Irfan Naeem Mangi Monday. These efforts, of course, plays a significant role in fighting bribery and corruption, however, Pakistan is still appearing in the headlines. Recently, Transparency International Pakistan has found the Federal Board of Revenue (FBR) involved in prima facia violating procurement rules for IT-based solutions and causing Rs13.5 billion losses to exchequer.

As the expert in AML and risk management solutions, CRI Group™ was interviewed in the Annual Review (2018): Pakistan Corporate Fraud & Corruption, published by Financier Worldwide Magazine and highlighted that Corporate fraud and corruption in Pakistan are widespread (Rose-Ackerman, 1997, p. 4), particularly in the government and police forces. There is a need to reform accountability and anti-corruption policies in Pakistan. 

Rising fraud risks have driven companies to establish the right steps to prevent fraud and corruption from surfacing. Following through with a focused trajectory ultimately also ensures failsafe protections are put in place, which will guard against scandals or negative publicity, while minimizing risk exposure. There is quite a notable empirical rise in the frequency of companies conducting background screenings to nip corruption in the bud. Though checks can vary in nature, enforcing internal controls by implementing ISO strategies can bring pivotal change to a company’s strategy. Risk management is an essential part of minimizing the costs that can arise in the long term due to losses and falling prey to fraudulent practices in the corporate realm. This can be implemented through a resilient management system that has been designed to specifically target any loopholes and any roadblocks, the impact of which can often be greater than anticipated, rattling the company and causing harm that could lead to lawsuits, unanticipated monetary and financial losses and hefty fines imposed by regulatory authorities, from which the company may never recover.

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Demonstrating Adequate Procedures to Prevent Bribery and Corruption 

ISO has developed a standard – ISO 37001:2016 ABMS – to help organisations promote an ethical business culture. “Designed to help your organisation implement an anti-bribery management system (ABMS), and/or enhance the controls you currently have. It helps to reduce the risk of bribery [and corruption] occurring and can demonstrate to your stakeholders that you have put in place internationally recognised good-practice anti-bribery [and anti-corruption] controls”.

Consider ISO 37001:2016 ABMS as one of the invaluable tools of your Third-Party Risk Management Strategy. Combined with due diligence, background screening, business intelligence and compliance solutions, ISO 37001 certification and training can lift your risk management process and help your business mitigate risks from third-party affiliations, protecting your organisation from liability, brand damage and harm to the business. Learn more about 3PRM™ program as a flexible and responsive tool to the various risk domains that are most important to your business.

ABAC™ – Aiming for a Higher Standard

At CRI Group’s ABAC™ Center of Excellence Limited, we are affiliated with leading certification and accreditation bodies around the world. These affiliations and accreditations help demonstrate the high level of experience and knowledge we provide in anti-bribery, risk and compliance management to our clients on a daily basis.

That’s why ABAC™ has achieved essential accreditations from the United Kingdom Accreditation Service (UKAS), Emirates International Accreditation Center (EIAC) and membership in the Association of British Certification Bodies (ABCB). ABAC® is also a member of the “Partner in Corporate Governance” programme with the Malaysian Institute of Corporate Governance (MICG) and a Corporate Member of Transparency International Malaysia (TI-M).

ABAC™ was established in 2016 by CRI Group™, a global leader in risk, compliance and anti-bribery management systems. ABAC™ was launched to provide certification and online training in anti-bribery and anti-corruption risk management and compliance for organisations worldwide. CRI Group™ and ABAC™ CEO Zafar I. Anjum, CFE, said that ABAC™ is proud to be accredited by, and affiliated with, international accreditation bodies. “Our engagement with high-profile bodies like EIAC, ABCB and UKAS demonstrates the effectiveness of our ISO 37001:2016 Anti-Bribery Management System certification and training, along with our ISO 37302, ISO 31000 certifications and other programs,” Anjum said. Visit abacgroup.com to find out more about anti-bribery, anti-corruption, risk and compliance management solutions.

CRI Group™ invites you to schedule a quick appointment with us to discuss in more detail how conducting due diligence and compliance can help you and your organisation. 

Meet our CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI Group™ (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI Group™ safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. Based in London, CRI Group™ maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, Turkey and the USA.

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