ANTI-CORRUPTION COMPLIANCE AND ENFORCEMENT IN THE NORDICS
R&C: What do you consider to be the key bribery and corruption issues to have emerged across the Nordic region over the past 12 months or so? What are the biggest challenges that companies, and their compliance professionals, in the Nordics face within this area?
Ghazvinian: In recent months, we have seen more companies investigated for corruption by US, Dutch or UK regulators than in the last 10 years. The biggest challenges will not be in the Nordic countries themselves, but in other countries where Nordic companies do business and therefore give another regulator jurisdiction over them. Compliance programmes that comply with the UK Bribery Act or the US Federal Sentencing Guidelines for Organizations (FSGO) will become standard. This is less about a programme and more about change management at the companies’ top level. Management will need to understand that more is required, especially if they do business in those countries.
Warberg: Financial institutions in the region are facing considerable scrutiny, particularly over transactions which may fall under the anti-money laundering (AML) regime. Over the last year, the biggest banks in the region have been subjected to strong criticism over AML, and some are still under investigation. What we have seen from these cases is the need for companies to manage their controls across professional areas, divisions and projects, in order to identify any irregularities. One key step companies should take is to give ethical training and increase awareness of anti-corruption efforts. Furthermore, the need for ongoing and daily control mechanisms is becoming even more important.
Apr-Jun 2018 Issue