Emma RadmoreThe Wolfsberg Group has updated its guidance for financial institutions on how to construct an effective ABC compliance programme. Recent papers focus on particular issues such as PEPs. This paper focuses on how institutions manage their ABC risks in respect of behaviour of employees and third parties acting on their behalf. It also looks at what prosecutors tend to regard as a “thing of value” as well as addressing what sorts of individuals might be considered to be public officials for ABC law purposes.
