Bribery is the offering, giving, receiving, or soliciting of something of value — money, gifts, hospitality, favours, or any other advantage — with the intention of improperly influencing the actions or decisions of a person in a position of trust or authority. Corruption is the broader concept encompassing bribery and other forms of abuse of entrusted power for private gain, including embezzlement, fraud, extortion, and conflicts of interest. Anti-Bribery and Corruption (ABC) refers to the legal framework and internal compliance measures designed to prevent, detect, and respond to such conduct. While ABC is a distinct discipline from AML, the two are closely intertwined — corruption is one of the most significant predicate offences for money laundering, meaning that the proceeds of bribery and corrupt activity are frequently the very funds that then need to be laundered through the financial system.
From a compliance perspective, the most globally influential ABC statutes are the UK Bribery Act 2010 — which applies to any company with a UK presence regardless of where the bribery occurs, and uniquely covers bribery of private individuals as well as public officials — and the US Foreign Corrupt Practices Act (FCPA) of 1977, which prohibits US persons and companies (and non-US companies listed on US exchanges) from bribing foreign government officials. At EU level, Directive 2017/1371 (the PIF Directive) criminalises corruption affecting the EU’s financial interests, and Framework Decision 2003/568/JHA requires Member States to criminalise active and passive corruption in the private sector. Businesses subject to ABC rules are typically required to implement a risk-based compliance programme covering policies and procedures, staff training, due diligence on third parties and business partners, gifts and hospitality controls, and whistleblowing channels. The penalties for violations — including for failing to prevent bribery, even without direct involvement — can be severe, encompassing unlimited fines and reputational damage.
