Anti-Bribery & Anti-Corruption (ABAC)
What you should know
Corruption undermines markets, trust, and leadership. Enforcement agencies are increasingly targeting executives — not just companies — for real or perceived failures to prevent bribery.
Why It Matters
A major aircraft manufacturer – €3.6B global settlement (2020) for bribery in 20+ countries
A multinational commodity trading and mining company – $1.1B (2022) for systemic bribery and fraud
A major aerospace and engineering firm – £671M (2017) for bribery across Asia, Africa, and the Middle East
ABAC enforcement now includes personal liability for directors who ignore red flags or fail to prevent misconduct.
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Core Requirements
Across jurisdictions, Anti-Bribery & Anti-Corruption (ABAC) regulations converge around three pillars:
Third-party intermediaries
(agents, distributors)
Public procurement and bidding
Offshore structures and shell companies
Strategic Implications
The U.S. FCPA has an aggressive extraterritorial reach, unlike other norms such as the UK Bribery Act or France’s Sapin II Law, which are less far-reaching.
“Failure to prevent” offenses increase board exposure
Compliance programs are no longer optional — they're a legal defense
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Your Leadership Checklist
Conduct risk assessments across markets and functions
Vet and monitor all intermediaries
Enforce a global code of conduct with anti-bribery clauses
Set tone from the top: zero tolerance is a board-level message
Want the full picture?
Download our executive guide to global anti-bribery enforcement and best practices.
