• Link to LinkedIn
  • Link to Youtube
  • Sign In
  • Register
  • Subscribe
  • Contact
Institute for Financial Integrity
  • Training
    • eLearning Courses

      • Suite of interactive e-learning courses to educate and engage staff on core compliance topics

      • Learn More
    • Video Library

      • An online learning journey through the various domains of financial crime, explore our library of expert-led videos

      • Learn More
    • Training Services

      • Trusted compliance training design, development, and delivery tailored to your unique requirements

      • Learn More
    • Certifications
      • Certified Risk Management Specialist – Global Sanctions
      • Certified Financial Integrity Professional Program
  • Technology
    • DOLFIN

      • A platform that equips financial integrity professionals with the continuing education, expert insights, resources and tools needed to protect the integrity of the global financial system.

      • Learn More
    • AskFIN

      • A revolutionary, AI-powered tool seamlessly integrated with DOLFIN® — the world’s largest and most trusted library of curated resources on financial integrity topics.

      • Learn More
  • Insights
    • Insights
      • Articles
      • Reports & White Papers
      • Webinars
      • Subscribe
  • About Us
    • Who We Are
      • Our Story
      • Leadership
      • Press Releases
    • Who We Serve
      • Financial Institutions
      • Jurisdictions
      • Executives
      • Industry Professionals
  • Get a Demo
  • Menu Menu

Upholding Integrity — Obligations in Combating Corruption and Bribery

How Financial Institutions and The Private Sector Can Protect Against Corruption

📅 May 29, 2024

Bribery and corruption represent a critical nexus where ethics, governance, and societal values intersect. These issues have long been a stain on both public and private sectors, creating distrust and distorting fair competition. International bodies and conventions typically define public sector corruption as the abuse of public office or a position of public trust for private gain. Global standards criminalize specific corruption offenses or corrupt acts such as bribery, theft of public funds, trading in influence, embezzlement, extortion, or other abuses of official functions.  

Bribery is the offering, giving, accepting, or soliciting, directly or indirectly, of anything of value in exchange for influence on a government employee, public official, or individual in a position of public trust. Different forms of bribery can be subtle yet impactful in influencing decisions and outcomes. Financial institutions, as key players in the economic ecosystem, bear a profound responsibility in combatting these insidious practices and upholding integrity. 

Bribery and corruption ultimately involve the misuse of power in favor of those who can afford to pay, hindering free economic development, eroding free markets by advancing unfair competition, and resulting in economic inefficiencies. 

Legal Implications and Prevention 

Engaging in bribery and corruption carries significant legal and ethical implications. From a legal standpoint, bribery is a criminal offense in most jurisdictions, punishable by hefty fines, imprisonment, or both.  

  • United States: The U.S. Foreign Corrupt Practices Act (FCPA) prohibits the bribing of foreign officials and establishes criminal and civil liabilities for payments of bribes by U.S. persons or companies to foreign government officials. The Foreign Extortion Prevention Act (FEPA) amends U.S. bribery law to make it illegal for any foreign official to demand, seek, receive, or accept a bribe from either a U.S. person or a U.S. company or from any person while in the United States, in connection with obtaining or retaining business. 
  • United Kingdom: The UK Bribery Act establishes company liability for bribery acts committed by persons acting on behalf of the company. A company can be held liable in the UK for acts of corruption committed by directors, employees, agents or subsidiaries anywhere in the world. 
  • European Union: The EU Convention against Corruption Involving Officials aims to ensure that each Member State takes the necessary measures to criminalize active (offering or paying a bribe) and passive (receiving the bribe) corruption involving public officials. 

In addition to national and regional regulations, financial institutions and other private-sector firms must emphasize the importance of compliance with anticorruption laws and ethical standards within their organizations. Implementing an effective robust anti-bribery and anticorruption compliance program, conducting proper due diligence on customers and business partners, and encouraging transparency and cooperation are key elements in preventing potential corruption.  

Case Study: SAP SE 

German software company SAP SE in January 2024 paid more than $220 million to settle investigations by the U.S. Justice Department and Securities and Exchange Commission (SEC) regarding violations of the Foreign Corrupt Practices Act. The investigations found that SAP paid bribes to officials in South Africa and Indonesia to secure government contracts. SAP entered a deferred prosecution agreement and will pay a criminal penalty and forfeiture. The company also agreed to ongoing cooperation and compliance measures, including restructuring and enhancing its compliance program. The case highlights international efforts to combat corruption and emphasizes the importance of corporate cooperation in investigations. 

The Biden administration in 2021 established the fight against corruption and kleptocracy as a core national security interest.  FinCEN in 2022 published an advisory to urge financial institutions to focus their efforts on detecting the proceeds of foreign public corruption. Financial institutions can decrease the risk of bribery and corruption by reporting suspicious activities, supporting anticorruption initiatives, and advocating for ethical business practices. Risks and red flags that should trigger additional scrutiny include: 

  • Third-party and supply chain – Most FCPA-related enforcement actions against corporations have involved third parties, and payments through intermediaries, including individuals and organizations acting in a representative capacity such as agents, consultants, and suppliers. 
  • Geography – The transaction or client is located in a country known for widespread corruption or funds are moving to and from countries with which the customer—especially a public official—does not appear to have ties. 
  • Industry – Some characteristics of industries that make them inherently higher-risk for bribery and corruption include the industry’s regulatory complexity and transparency, the involvement of governments or state-controlled entities in the industry, the industry’s scale, and its complexity in terms of typical supply chain and delivery channel relationships.  
  • Customer – the customer has a reputation for unethical conduct, a history of improper payment practices, or has shown a willingness to violate the law. 
  • Politically Exposed Persons (PEPs) – the use of third parties to shield the identity of foreign public officials seeking to hide the origin or ownership of funds or accounts held in the name of intermediate legal entities whose beneficial owner may be tied to a kleptocrat or a family member. 

Real-Life Dangers of Corruption 

Corruption can result in not just inefficiencies, but also loss of life. For example, corruption played a significant role in Türkiye’s February 2022 earthquakes, involving connected construction companies, inadequate audits, and impunity for completed construction projects that may have not been up to code, leading to a decline in anti-corruption rankings. Despite being prone to earthquakes, the country has failed to enact crucial legal reforms and enforce building regulations effectively. The 2018 Zoning Amnesty further exacerbated the situation by legalizing unsafe constructions without proper earthquake checks. Moreover, funds allocated for earthquake prevention were diverted to unrelated projects, resulting in devastating consequences during recent earthquakes.  

The International Monetary Fund (IMF) has also written a working paper discussing the devastating effects corruption and natural disasters. The working paper assessed that corruption increases the number of disaster-related deaths by undermining the quality of public infrastructure, the effectiveness of emergency responses and healthcare services after a natural disaster, and the adherence to building codes. 

Overcoming the challenges posed by corruption and bribery demands a united front involving governments, businesses, and individuals committed to fostering transparency and upholding ethical standards. 

Visit DOLFIN’s Foundations of Anti-Bribery and Corruption chapter to read more about global standards, risks, and compliance standards.  

Corruption in Construction

View our webinar designed to equip financial institutions with the essential strategies for combating corruption in construction.

The construction and infrastructure sector faces significant corruption challenges, including bribery, fraud, and extortion. Studies suggest that corruption incurs losses ranging from 10 – 30% within the construction domain. With the sector projected to yield nearly $17.8 trillion annually by 2030, the perpetuation of current corruption trends threatens a potential annual loss of close to $6 trillion. These issues are compounded by complex project structures and inadequate anti-corruption measures.

Bribery and corruption pose significant risks to financial institutions, including reputational damage, legal and regulatory consequences, and financial losses. Effective compliance measures are essential to mitigate these risks and uphold ethical standards within the financial industry.

Led by industry experts, this webinar will provide targeted insights into the unique challenges faced by financial institutions and practical solutions for ensuring compliance and reducing risk through an exploration on case studies, the key drivers of fraud and corruption, and U.S. regulatory requirements and compliance measures.

View the Recording

Recommended Blogs

Dirty Barrels

September 24, 2026
While oil and gas is one of the world's most valuable and strategically important industries, it is vulnerable to corruption. Explore how corruption risks can arise throughout the lifecycle of an oil and gas transaction.
Read more
https://finintegrity.org/wp-content/uploads/2026/09/shutterstock_2645005987-scaled.jpg 1706 2560 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2026-09-24 07:00:302026-09-24 11:44:27Dirty Barrels

Social Engineering Is Rewriting the Fraud Playbook

July 8, 2026
Fraudsters have shifted from breaching systems to manipulating people. This article examines how social engineering, from deepfake video calls to business email compromise, is outpacing traditional defenses, and what it takes to train employees to recognize and resist it.
Read more
https://finintegrity.org/wp-content/uploads/2026/06/social-engineering-bg-1.jpg 675 1200 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2026-07-08 07:00:562026-07-08 07:57:51Social Engineering Is Rewriting the Fraud Playbook

Synthetic Identities

January 8, 2026
Fraud generates billions in proceeds every year, and the use of AI significantly increases the speed, scale, and likelihood of success. Synthetic identities are already leveraged to open accounts used to commit fraud and launder money. Explore red flags and actions financial institutions must take to detect and respond to AI-enabled synthetic identities.
Read more
https://finintegrity.org/wp-content/uploads/2026/01/bg-synethic-identities.jpg 500 1200 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2026-01-08 07:00:252026-03-27 12:40:46Synthetic Identities

When Holiday Cheer Meets Fraud Pressure

November 26, 2025
This article breaks down the key scam patterns emerging this season, why December has become a true test of institutional readiness, and the steps teams can take to reduce losses and respond with confidence.
Read more
https://finintegrity.org/wp-content/uploads/2025/11/holiday-cheer-bg.jpg 1013 1800 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-11-26 07:00:442026-03-27 12:44:38When Holiday Cheer Meets Fraud Pressure

Operation Mouse

October 8, 2025
Synthetic identities are increasingly used to perpetrate fraud. Delve into real-life examples of synthetic identity fraud in Canada, along with the actions financial institutions can take in response, in this article.
Read more
https://finintegrity.org/wp-content/uploads/2025/09/bg-operation-mouse.jpg 1265 1800 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-10-08 07:00:322025-10-06 14:29:44Operation Mouse

Deepfake Deep Dive

August 27, 2025
Artificial intelligence (AI) can increase the volume, value, and effectiveness of fraud attacks such as CEO fraud. Financial institutions should take action to protect themselves – and their customers.
Read more
https://finintegrity.org/wp-content/uploads/2025/08/shutterstock_2599430089-scaled.jpg 1202 2560 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-08-27 07:00:452026-05-14 14:14:01Deepfake Deep Dive

From Fraud to Flow

June 18, 2025
Fraud is often the entry point into a complex web of financial crime from money laundering to terrorism financing. Understanding this gateway role is essential for those defending the integrity of the global financial system.
Read more
https://finintegrity.org/wp-content/uploads/2025/06/shutterstock_1107463670-scaled.jpg 1707 2560 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-06-18 07:00:192025-09-25 15:27:13From Fraud to Flow

The Heat is On

February 24, 2025
Explore the key insights and implications from Transparency International’s 2024 Corruption Perceptions Index.
Read more
https://finintegrity.org/wp-content/uploads/2025/02/the-heat-is-on-bg.jpg 1157 1800 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-02-24 07:00:152025-03-26 19:38:52The Heat is On

The Green Gold Rush

January 13, 2025
Explore the corruption risks in the green transition mining and minerals sector, a rapidly growing industry fraught with challenges that expose businesses to bribery, fraud, and reputational damage. Discover strategies to protect your operations and ensure compliance in the race for sustainable energy solutions.
Read more
https://finintegrity.org/wp-content/uploads/2025/01/article-green-gold-rush.jpg 1261 1800 IFI https://live-black-pebble.pantheonsite.io/wp-content/uploads/2023/12/GIFI-Placeholder2.png IFI2025-01-13 07:00:472025-09-25 15:00:34The Green Gold Rush
Previous Previous Previous Next Next Next
Download IFI Compliance Checklist Report

Follow Us on LinkedIn

Share this article

  • Share on LinkedIn
  • Share by Mail

Recent Articles

  • September 2026 Monthly Sanctions and Export Controls Report
  • The Data Behind the Payment
  • Dirty Barrels
  • Real Estate, Real Risks
  • Iran and the Sanctions Landscape

Explore Other Topics

  • Artificial Intelligence
  • Compliance Best Practices
  • Corruption
  • Digital Assets
  • Drug Trafficking
  • European Union
  • Fraud
  • Human Trafficking
  • Money Laundering
  • Oil and Gas
  • Press Releases
  • Proliferation Finance
  • Regulation
  • Russia
  • Sanctions
  • Strategic Trade Controls / Export Controls
  • Terrorism

View Our Expert Insights

  • Compliance Training Readiness Checklist
  • Inside the Cartels and Chinese Money Laundering Networks Driving Criminal Economies
  • High Stakes – Casinos, Crime, and Cartels
  • From Cost Center to Risk Control
  • Leveraging Artificial Intelligence for Enhanced Financial Compliance
  • The Convergence of Sanctions and AML/CFT Regimes
  • Casinos and Cryptocurrency Driving Illicit Finance in East and Southeast Asia
  • Russia 2024: The Two-Year Anniversary of the Invasion
  • Human Trafficking Crisis after Russia’s Invasion of Ukraine
  • 2024 Trends Report
© DOLFIN Academy LLC 2026
  • Link to LinkedIn
  • Link to Youtube
  • Privacy Policy
Link to: Russian Use of Crypto for Sanctions Evasion on the Rise Link to: Russian Use of Crypto for Sanctions Evasion on the Rise Russian Use of Crypto for Sanctions Evasion on the Rise Link to: Types of Sanctions – A Vast and Varying Landscape Link to: Types of Sanctions – A Vast and Varying Landscape Types of Sanctions – A Vast and Varying Landscape
Scroll to top Scroll to top Scroll to top

This site uses cookies. By continuing to browse the site, you are agreeing to our use of cookies.

Accept settingsHide notification onlySettings

Cookie and Privacy Settings



How we use cookies

We may request cookies to be set on your device. We use cookies to let us know when you visit our websites, how you interact with us, to enrich your user experience, and to customize your relationship with our website.

Click on the different category headings to find out more. You can also change some of your preferences. Note that blocking some types of cookies may impact your experience on our websites and the services we are able to offer.

Essential Website Cookies

These cookies are strictly necessary to provide you with services available through our website and to use some of its features.

Because these cookies are strictly necessary to deliver the website, refusing them will have impact how our site functions. You always can block or delete cookies by changing your browser settings and force blocking all cookies on this website. But this will always prompt you to accept/refuse cookies when revisiting our site.

We fully respect if you want to refuse cookies but to avoid asking you again and again kindly allow us to store a cookie for that. You are free to opt out any time or opt in for other cookies to get a better experience. If you refuse cookies we will remove all set cookies in our domain.

We provide you with a list of stored cookies on your computer in our domain so you can check what we stored. Due to security reasons we are not able to show or modify cookies from other domains. You can check these in your browser security settings.

Google Analytics Cookies

These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customize our website and application for you in order to enhance your experience.

If you do not want that we track your visit to our site you can disable tracking in your browser here:

Other external services

We also use different external services like Google Webfonts, Google Maps, and external Video providers. Since these providers may collect personal data like your IP address we allow you to block them here. Please be aware that this might heavily reduce the functionality and appearance of our site. Changes will take effect once you reload the page.

Google Webfont Settings:

Google Map Settings:

Google reCaptcha Settings:

Vimeo and Youtube video embeds:

Privacy Policy

You can read about our cookies and privacy settings in detail on our Privacy Policy Page.

Privacy Policy
Accept settingsHide notification only