The American Journal of Political Science Law and Criminology
16
https://www.theamericanjournals.com/index.php/tajpslc
TYPE
Original Research
PAGE NO.
16-22
10.37547/tajpslc/Volume07Issue04-04
OPEN ACCESS
SUBMITED
12 February 2025
ACCEPTED
13 March 2025
PUBLISHED
10 April 2025
VOLUME
Vol.07 Issue04 2025
CITATION
M.R. Rasulov. (2025). International standards and recommendations for
implementing compliance control systems in the banking sector. The
American Journal of Political Science Law and Criminology, 7(04), 16
–
22.
https://doi.org/10.37547/tajpslc/Volume07Issue04-04
COPYRIGHT
© 2025 Original content from this work may be used under the terms
of the creative commons attributes 4.0 License.
International standards
and recommendations for
implementing compliance
control systems in the
banking sector
M.R. Rasulov
Law Enforcement Academy of the Republic of Uzbekistan, Uzbekistan
Abstract:
This paper explores the international
standards and recommendations for implementing
compliance control systems in the banking sector.
Compliance control systems are essential for ensuring
that banks operate within legal and regulatory
frameworks, thereby maintaining financial stability and
integrity. The study examines key guidelines and best
practices from global regulatory bodies, such as the
Basel Committee on Banking Supervision, the OECD, the
Wolfsberg Group, the World Bank, and the Financial
Action Task Force, highlighting their significance in
fostering a robust compliance culture. Furthermore, it
analyses the challenges and benefits associated with
adopting these standards, providing insights into
effective implementation strategies for banking
institutions.
Keywords:
Compliance control systems, banking sector,
international standards, regulatory frameworks, Basel
Committee on Banking Supervision, Financial Action
Task Force, OECD, The Wolfsberg Group, compliance
culture, legal regulations.
Introduction:
The banking sector, which serves as the
foundation of global economic stability, operates within
a complex network of regulations and standards aimed
at ensuring its integrity, transparency, and reliability. In
an era characterised by globalisation and technological
advancement, implementing robust compliance control
systems has become crucial. International standards
and recommendations play a significant role in forming
these systems, ensuring uniformity, improving risk
management, and ensuring the overall security of the
sector.
Extensive research conducted by scientists has shown
The American Journal of Political Science Law and Criminology
17
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
that corruption acts as a factor negatively impacting
global financial crises and the balance of banks.
Specifically, it has been determined that the primary
cause of the East Asian financial crises in 1997-1998
was corruption.
For instance, the corruption cases associated with the
"Hanbo" corporation in the Republic of Korea,
characterized by "strong ties" between companies and
politicians, serve as a typical example of how these
connections led to a serious deterioration in the quality
of bank assets and ultimately to a financial crisis.
Similarly, we can observe this in the example of the
"Global Financial Crisis" that occurred in 2008.
Based on the above circumstances, we will
hierarchically outline the international norms and
recommendations aimed at preventing corruption
risks in banks, according to the authority and power of
the organizations that develop them.
The UN Convention against Corruption. The
Convention was adopted by the General Assembly in
its resolution 58/4 of 31 October 2003.
It should be noted that during this period, the necessity
of implementing the convention arose not only to
enhance and improve our country's international
reputation in the fight against corruption but also, on
the other hand, it became evident that effective
preventive measures against such crimes, rather than
merely dealing with their consequences, should be
applied.
An
Anti-Corruption
Ethics
and
Compliance
Programme: U
NODC’s Practical Guide for Business
explains that the development of recommendations
for combating corruption on an international scale is
due to the increasing incidence of corruption-related
offenses. With the adoption of the United Nations
Convention against Corruption, the necessity for
strengthening anti-corruption measures has been
firmly established not only for state institutions but
also for participants in the private sector at an
international level. The convention's articles, such as
"Private Sector" (Article 12), "Bribery in the Private
Sector" (Article 21), "Embezzlement of Property in the
Private Sector" (Article 22), and "Cooperation between
National Authorities and the Private Sector" (Article
39), provide recommendations for identifying and
preventing corruption risks and implementing
preventive measures within the activities of private
sector participants.
They consist of the following:
- Implementing measures to encourage cooperation
between state and private sector participants in
combating corruption-related crimes;
- Establishing standards aimed at ensuring transparency
and openness in their activities and preventing conflicts
of interest, and encouraging these measures;
- Preventing conflicts of interest that may arise from the
commercial activities of officials in state organizations;
- Introducing internal control mechanisms within the
organization's activities, as well as implementing
procedures for auditing and certifying their economic
activities and financial reports.
In general, the convention specifically emphasizes the
necessity of implementing measures to ensure the
transparency of accounting and financial reporting,
accounting standards, internal audit, and internal
control mechanisms to minimize corruption-related
offenses in the activities of any organization.
Accepted standards and recommendations by the
Organisation
for
Economic
Co-operation
and
Development (OECD).
The Convention on Combating Bribery of Foreign Public
Officials in International Business Transactions
recommends taking strict measures to prevent and
minimize corruption risks. The Convention emphasizes
the importance of implementing internal oversight
mechanisms, such as:
- Developing and adopting corporate ethical standards
(codes of conduct).
- Disclosing information on the operation of internal
oversight mechanisms in annual reports.
- Establishing systems that encourage reporting of
corruption cases by individuals who do not tolerate
breaches of professional and ethical norms, ensuring
their protection under whistleblower systems.
It's possible that the preventive measures outlined here
could be organized under a "compliance-audit" system.
Another document intended to regulate this area is the
Good Practice Guidance on Internal Controls, Ethics, and
Compliance.
Joe Murphy and Donna Boehme’s scholarly article,
"Commentary on the OECD good practice guidance on
internal controls, ethics and compliance," emphasizes
the critical need for proactive measures against
corruption in the private sector. Specifically, it highlights
various forms of corruption, such as gift and hospitality
practices, different types of bribery, and facilitation
payments. The article underscores the importance of
adhering to regulations, such as those outlined in
compliance oversight systems, to effectively combat
corruption.
In this case, it is especially emphasized that the
organization should take this aspect into account in
order to implement the comprehensive preventive
The American Journal of Political Science Law and Criminology
18
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
system in its activities.
The next document published by this international
organization is the 2011 Regional Document of the
Anti-Corruption Partnership "Global Anti-Corruption
Policy Declaration" .
In this document, there is a separate provision entitled
"Privacy, extortion, bribery, and bribery" in which the
following aspects of bribery and its prevention in the
organization's activities are specified separately:
1. Limitation of the risk of co-operation between the
civil servant and the official representative.
2. Prohibition of the use of third-party force for sexual
intercourse.
3. Prohibition of public payment or minimization at the
lowest level.
4. Due diligence - assessment of the reliability of the
third party.
5. Development of a closed "complacency-nazopath"
dactuplap to prevent the risk of coppuption during
operation.
6. Ensuring transparency of activity and regular
reporting to the public.
In this way, the OECD’s "Guidelines on corporate
governance of state-owned enterprises" emphasizes
the importance of closing the "compliance" document
and the code of ethics in order to ensure the activity of
the state and legal cooperation in the field of
cooperation.
Another important document aimed at preventing co-
optation in the state and public sector is the Global
Principles for Combating Corruption, developed in
2004 by the Partnering Against Corruption Initiative.
The public document includes members of the World
Economic Forum, Texas Instruments Incorporated is an
American technology company, and representatives of
the Basel Institute on Governance.
In 2013, this document was revised according to public
demand, and "Principles of PACI" was published. In
this case, 6 key principles of the implementation of the
"compliance-control" system for business-oriented
companies were included in the document.
1.
Tone at the top
- demonstrating to the team, as a
personal example, the leadership of the organization's
leadership in relation to cooperation.
2. Zero tolerance to corruption
- formation of a culture
of "0 (zero)" level of tolerance to corruption.
3. Transparency
- ensuring open and transparent
organization of activities.
4. Compliance
- to ensure that the organization's
activities comply with the law at the maximum level.
5.
Counterparty
- establishing a relationship with a
business partner who is highly ethical and adheres to
the principles of cooperation.
6. Support and encourage regular copulation initiative.
This principle mentioned above serves to determine the
factor, caballap, which is the result of co-optation, but
also the cause of co-optation.
The document "Compliance and the compliance
function in banks The Basel Committee on Banking
Supervision adopted in the 2005 appeal of the Basel
Committee" (in a new version) is another document that
will implement the "Compliance-supervision" system.
The recommendation applies to the activities of banks
and credit organizations, and it is aimed at reducing the
risk of corruption, preventing corruption violations, and
organizing the company's activities in accordance with
established rules and regulations.
The Basel Committee on Banking Supervision identifies
the main directions of the "compliance risk
management" service within the framework of its
activity, determining the key areas of its competence:
adherence to laws, internal regulations, compliance
with ethical standards, prioritizing the exchange of
benefits, ensuring equality in relations with clients,
providing assistance to clients in an equitable manner,
organizing the elements of community oversight in
ensuring compliance, striving to legalize social income
and entrepreneurship, and implementing supervision
based on employees' compliance with established laws
and regulations.
The Basel Committee on Banking Supervision provides
several guidelines to combat corruption and money
laundering in banks. We classify them into the following
four main groups in a conditional manner: 1) Internal
(conduct and ethical rules, conduct and ethical issues for
senior personnel, conduct and ethical issues for
supervisory entities, whistleblowing on integrity and
corruption), 2) External (adherence to the Due diligence
principle, Non-compliant jurisdiction policy, meaning
the absolute policy of not tolerating, establishing an
AML/CTF policy, meaning how your AML/CTF policy
deals with income derived from legitimate financial
activities and addressing risks of terrorism financing. It
also encompasses developing and adopting policies,
procedures, and management tools for identifying,
reducing, and managing these risks, whistleblowing on
integrity and corruption), 3) Examination (policy of
investigation and execution, separate examination
section in ethical issues for senior personnel is
necessary), 4) Incorporating IFI standards internally
(establishing a unified system for combating fraud and
corruption and resisting them).
The American Journal of Political Science Law and Criminology
19
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
The emphasized indicators themselves also belong to
special interest groups, and it is of great importance in
preventing corruption in the activities of banks. For
example, general principles of Compliance supervision
and legality include adhering to the relevant market
–
conduct standards, managing conflicts of interest,
combating money laundering, financing terrorism, and
effectively combating corruption. These are identified
by laws, regulatory documents, and self-regulatory
organization standards.
The establishment of compliance units in banks, as
recommended by the Basel Committee on Banking
Supervision, is essential for identifying the position of
the compliance oversight function within banks and for
ensuring its independence. Merely assigning the
responsibility of combating corruption to compliance
officers is insufficient; rather, it is necessary for the
bank to incorporate compliance into its corporate
culture. This means clearly defining the role, rights, and
responsibilities of the compliance oversight unit, as
well as creating mechanisms to ensure its
independence and autonomy.
The Basel Committee's 2005 document "Compliance
and the compliance function in banks and securities
firms" provides the following recommendations for
establishing a system to combat corruption:
a)
Establishing
mechanisms
to
ensure
the
independence and autonomy of the compliance
oversight function, including defining its position,
rights, and responsibilities within the bank's legal
framework;
b) Defining internal procedures for identifying internal
conflicts of interest within the compliance oversight
unit, for example, through internal audit procedures;
c) Clarifying the conditions for implementing
compliance functions by various divisions of the bank,
ensuring that tasks are clearly defined by
management, and aligning the performance of these
functions with the objectives of the institution, as the
proper functioning of tasks contributes to the integrity
and independent operation of the organization;
d) Ensuring access to necessary information for
compliance officers to carry out their duties and
establishing the obligation to provide employees with
information
related
to
corruption,
ensuring
cooperation in identifying and reporting corruption-
related information;
e) Providing the right to present evidence and report
to authorities in cases of corruption without fear of
retaliation;
f) Defining the position of the compliance oversight
function in reporting to authorities.
These recommendations are crucial for establishing an
effective compliance framework within banks and other
financial institutions, enabling them to effectively
combat corruption and maintain integrity in their
operations.
In general, it can be said that the rules proposed by the
Basel Committee for the establishment of a
"compliment-control" system, which is strict about the
organizational form, the organization in the form of a
branch, and the cooperation in the operation of the
company, also determine its uniqueness. Because the
document prescribes the full organization of the
"complience" system at the maximum level of this
recommendation.
Moreover, it is necessary to emphasize at this point that
the Bureau has not restricted its activities solely to
organizing a seminar on "compliance in banking" and
"compliance functions," as stated in the document of
the Basel Committee. Its significance lies not only in the
structure and content of this document but also in its
advisory importance, which has been underscored.
In today's CIS member states, the bank employees are
not adhering to this recommendation, aimed at curbing
corruption, but instead are actively working to establish
a compliance oversight system in their activities.
For example, such banks as Citibank or HSBC Holdings,
which have public economic capital.
The next most important document in the fight against
bribery is ISO 37001 Anti-bribery management systems.
When international expert I. Burdikova explores the
content of the standard, she emphasizes the following:
ISO 37001:2016 "Anti-bribery management systems" is
a standard that provides guidelines for establishing
effective and preventive systems for combating bribery
within
organizations
(whether
governmental,
corporate, or non-profit). This standard serves as a
framework for developing comprehensive anti-bribery
systems and can be instrumental in providing services
for the establishment of such systems. The application
of this standard may not only improve the organization's
image but also contribute to the participation of
government,
corporate,
or
non-profit
sector
stakeholders in anti-bribery activities and facilitate their
involvement in combating bribery within the
institutional framework.
ISO 37001:2016 is an international standard aimed at
preventing corruption risks in organizational activities. It
outlines the following approaches to be used in dealing
with corruption:
- Receipt of bribes by employees from government,
private, and non-profit sectors;
- Receipt of bribes by employees working for or on
The American Journal of Political Science Law and Criminology
20
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
behalf of an organization;
- Receipt of bribes by collaborators (contractors)
working for or on behalf of the organization;
- Providing bribes to employees and officials related to
the organization's activities;
- Providing bribes to collaborators (contractors)
associated with the organization's activities;
- Situations such as giving or receiving bribes directly or
indirectly (for example, bribes offered or accepted by
a third party).
This standard applies to all types of organizations
regardless of their form, whether governmental,
private, or non-profit sectors.
The Group of the World Bank (hereinafter referred to
as the Group) has, over the past
20 years or more, worked to mitigate the harmful
effects of corruption in member countries and has
developed institutions capable of reporting, as well as
implementing policies against corruption.
The group's activities provide practical assistance in
improving the situation of combating corruption, both
by providing comprehensive and evolving information
to both state and non-state actors, enhancing policies
and practices that strengthen societal integrity. In
addition, the group works with states, private sectors
(banks), and civil society to develop standards and
measures to combat corruption, as well as to
implement them.
Our research findings indicate that grants and loans
provided by the World Bank to developing countries
have become essential for their economies to thrive.
Therefore, it is important for the World Bank to
evaluate countries in terms of their policies and
strategies to combat corruption and to provide the
necessary recommendations. These recommendations
include:
1) Enhancing public knowledge about corruption
through various seminars;
2) Developing the knowledge of public servants about
corruption through various seminars, training, and
promotional methods;
3) Installing ethical standards in the fight against
corruption;
4) Increasing the salaries of public servants;
5) Reducing the turnover of staff, i.e., addressing
turnover rates lower than average living standards;
6) Establishing a fair civil society;
7) Taking into account the opinions of the population
as a key indicator;
8) Establishing transparent financial reporting;
9) Parliamentary oversight of corruption;
10) Improving public services, increasing efficiency in
the private sector;
11) Enhancing accountability of public servants;
12) Eliminating bureaucratic barriers;
13) Reforming economic policies;
14) Ensuring the independence of public information
sources;
15) Finally, ensuring legal integrity is also considered
very important.
Apart from this, it is necessary to implement the
recommendations provided in the guidelines for
combating fraud and corruption in projects financed by
IBRD loans and credits of the International Development
Association, as well as grants, which are accounted for
in the structural component of the World Bank, and
credits and grants of the International Development
Association.
We will cover only the part of these recommendations
relevant to banks, actions to prevent corruption by
borrowers include:
1) Measures to be taken to prevent fraud and corruption
in sectors where the diversion of funds is possible,
especially obligations imposed on the borrower to take
certain actions, including mandatory reporting of
certain activities relative to the lender, and the
specification of financial arrangements between the
borrower and the bank.
2) Obligation for the borrower to participate in anti-
corruption measures in projects, ensuring that anti-
corruption guidelines are provided to project staff and
non-governmental/non-commercial
organizations,
financial intermediaries, and other participating
organizations, including their staff working on the
project.
The Financial Action Task Force (FATF)
is an
international intergovernmental organization formed to
combat money laundering and terrorism financing.
Considered as the governmental organization, FATF
establishes international standards aimed at preventing
the use of financial systems for illicit activities and the
harm they pose to society. FATF is recognized as one of
the most influential organizations capable of exerting
significant influence on over 200 jurisdictions. Its
recommendations primarily target crimes such as
money laundering, corruption, and terrorism, aiming to
prioritize the legalization of illicit funds.
FATF recommendations primarily focus on the external
activities of banks and advocate for the proper seizure
of national assets in a clandestine manner. We know
that the legalization of revenues from criminal activities
The American Journal of Political Science Law and Criminology
21
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
and the financing of terrorism often occur through
banks directly, and FATF has developed several
standards to prevent such illicit activities. These
include:
1) Identifying crimes related to the legalization of
revenues from criminal activities,
2) Ensuring accountability for individuals involved in
these crimes,
3) Conducting temporary freezes and investigations,
4) Ensuring compliance of national financial
institutions with laws regarding financial secrecy
according to FATF recommendations,
5)
Employing
due
diligence
principles
and
considerations when working with clients,
6) Implementing regular checks on politically exposed
persons by financial institutions,
7) Paying special attention to any legal threats posed
by new or evolving technologies that could be used in
money laundering schemes,
8) Maintaining records of information requests from
competent authorities promptly for at least five years
for internal or international operations,
9) Providing necessary permissions for the re-
examination of individual transactions if there are
indications of suspicious financial activities,
10) Paying special attention to all complex, unusual, or
non-transparent operations and reporting them
promptly.
These are just a few of the guidelines set forth by FATF
to combat financial crimes.
One of the international organizations combating
money laundering and corruption derived from
general activities is the Wolfsberg Group
, consisting of
13 major banks (Banco Santander, Bank of America,
Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup,
Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP
Morgan Chase, Société Générale, Standard Chartered,
and UBS). Its aim is to develop financial-economic
standards for combating money laundering (AML),
including financial standards for banks, customer due
diligence (KYC), and anti-money laundering policies
(CTF). Although the organization's activities align with
FATF's, it operates as an independent div within the
framework of government regulation. The Wolfsberg
Group serves as a collective initiative group in
combating corruption outside of AML activities. It is
preferable for the group to conduct its activities
discreetly without publicizing them through the media.
The following actions are recommended for the
implementation of the ABC - ANTI-BRIBERY AND
CORRUPTION PROGRAM developed by the Wolfsberg
Group:
1) Establish effective leadership - appoint a person with
authority, experience, and expertise to oversee senior
management supervision within the framework of this
program,
2) Assess risks, meaning to evaluate the nature, scope,
and specific characteristics of corruption and bribery
risks that may arise periodically within each bank,
3) Enhance the anti-corruption education system and
raise awareness about these violations,
4) Establish a compliance monitoring system,
5) Evaluate corruption risks that may arise in
interactions with bank clients,
6) Resolve issues of roles and responsibilities, meaning
ensuring accountability in management for subjects
implementing
bank
policies,
and
resolving
accountability issues for lower-ranking employees who
have deviated from their duties,
7) Strengthen the internal and external reporting
system on corruption,
8) Improve reporting systems to law enforcement
agencies about violations and ensure transparency of
information,
9) Evaluate relationships with third-party providers
(suppliers, contractors, sellers, or distributors),
10) Regulate gifts and business hospitality,
11) Clarify procurement procedures,
12) Regulate charity systems,
13) Monitor actions to prevent the misuse of funds in
cases where organizations allocate money for
commercial purposes,
14) Improve marketing compliance,
15) Prioritize the legalization of processes related to
income acquisition and other activities.
CONCLUSION
In summary, adherence to international standards and
recommendations is crucial within the banking sector's
compliance control systems. These standards establish
a common framework, bolster risk management,
promote transparency, and safeguard consumer
interests. Despite the challenges, the benefits of
adhering to these standards far outweigh the associated
costs, contributing to a globally stable, transparent, and
reliable banking system. As the financial landscape
evolves, the significance of international standards in
preserving the integrity and stability of the banking
sector will only increase.
REFERENCES
Literature on bank crises shows that the deterioration of
The American Journal of Political Science Law and Criminology
22
https://www.theamericanjournals.com/index.php/tajpslc
The American Journal of Political Science Law and Criminology
the balance sheet is one of main symptoms of a
financial crisis.
Hanbo Corporation, a business conglomerate, financed
enormous amounts of funds using its strong ties to
high ranking officials, politicians, lawmakers, and even
the then-
president’s son. T
he secret relationship
revealed during the prosecution in 1997 had been
maintained by bribes that Hanbo provided to them.
[Electronic
resource].
URL:
https://www.forbes.com/2009/01/27/corruption-
financial-crisis-business
corruption09_0127corruption.html?sh=6b836aea61b
3
An
Anti-Corruption
Ethics
and
Compliance
Programme: UNODC’s Practical Guide for Business
[Electronic
resource].
URL:
https://www.unodc.org/documents/corruption/Publi
cations/2013/13-84498_Ebook.pdf
OECD (2016) Committing to Effective Whistleblower
Protection [Electronic resource]. URL: https://www.
oecd. Org/corruption/anti-bribery/Committing -to-
Effective-Whistleblower-Protection-Highlights.pdf
Good Practice Guidance on Internal Controls, Ethics
and
Compliance.
[Electronic
resource].
URL:
http://www.oecd. org.pdf
Joe Murphy and Donna Boehme “Commentary on the
oecd good practice guidance on internal controls,
ethics and compliance” –
Rutgers Journal of Law &
Public Policy, Spring 2012, [Electronic resource]. URL:
https://rutgers
policyjournal.org/sites/jlpp/files/9-
4_Murphy_RTPv2.pdf
Partnering Against Corruption Initiative Global
Principles for Combating corruption. World Economic
Forum, May 2016 [Electronic resource]. URL:
http://www3.weforum.org/docs/WEF_PACI_Global_P
rinciples-_for_-Corrup-tion. pdf
OECD (2014) Guidelines on corporate governance of
state-owned enterprises// [Electronic resource]. URL:
https: // www.oecd.org
Partnering Against Corruption Initiative Global
Principles for Combating corruption. World Economic
Forum,
May
2016
[Electronic
resource].URL:
http://www3.weforum.org/docs/WEF_PACI_Global_P
rinciples.pdf
Partnering Against Corruption Initiative Global
Principles for Combating corruption. World Economic
Forum, May 2016 [Electronic resource]. URL:
http://www3.weforum.org/docs/ WEF PACI Global
Principles for Countering Corruption.pdf
Compliance and the compliance function in banks The
Basel Committee on Banking Supervision [Electronic
resource]. URL: https://www.bis.org/publ/bcbs113.htm
[Electronic resource]. URL: https://www.bis.org/The
role of bank supervisors in the fight against corruption.
Базельский
комитет
по
банковскому
надзору//Руководство Принципы корпоративного
управления для банков [Electronic resource]. URL:
https://www.cbr.ru/Content/Document/File/36687/Ba
sel_cgpb.pdf
Т.А.Хабриевой, А.В. Федорова Антикоррупционные
стандарты Организации экономического сотруд
-
ничества и развития в Европе // монография, 2015.–
c.74. [Electronic resource]. URL: https://znanium.com
ISO
37001
Anti-bribery
management
systems
[Electronic resource]. URL: https://www.iso.org/iso-
37001-anti-bribery-management.html
World Bank Group July 1
–
22, 1944 Bretton Woods
International Agreement.
Jeff Huther, Anti-Corruption Policies and Program, A
Framework for Evaluation, The World Bank Operations
Evaluation Department Country Evaluation and
Regional Relations Division, December
–
2000.
The International Bank for Reconstruction and
Development (IBRD) is an international financial
institution, established in 1944 and headquartered in
Washington, D.C., United States, that is the lending arm
of World Bank Group. The IBRD offers loans to middle-
income developing countries.
The World Bank`s Anti
–
corruption Guidelines and
Sanctions Reform (Actions for Borrowers & Other
Recipients of loans to help prevent and combat
corruption in bank financed Projects).
The FATF was established in 1989 at the G7 summit in
Paris to combat the growing problem of money
laundering.
wolfsberg-principles.com. Wolfsberg Anti-Bribery and
Corruption (ABC) Compliance Programme Guidance
(The Wolfsberg Group 2017).
