Penalties from regulators worldwide, resulting from anti-bribery law violations are staggering. Corporate enforcement actions by the US DOJ/SEC have soared within the last 12 months. Prosecutions of more than a dozen companies have resulted in combined record-breaking penalties from the DOJ/SEC of almost 4 billion USD. The DOJ/SEC has levied criminal charges against 34 individuals with 30 pleading guilty and facing monetary fines as well as, in some cases, prison time.

In April of 2019 the DOJ Criminal Division issued updated guidance on how prosecutors evaluate Corporate Compliance programs. The new guidance is basically structured around 3 key questions:

1. Is the corporation’s compliance program well designed

2. Is the program being implemented effectively?

3. Does the corporation’s compliance program work in practice?

Let’s consider these 3 key questions. How can you determine if your compliance program is well designed, implemented effectively and is working properly when it comes to bribery prevention? An effective approach to addressing all 3 questions is adoption of the ISO standard 37001:2016. This ISO standard is a globally accepted common framework that provides the tools to design and implement a Management System to mitigate bribery risks. ISO 37001 requires the implemented Anti-bribery Management System to be periodically monitored, tested on its effectiveness and improved, as internal and external factors continually affect the company’s bribery risk.

The benefits of implementing ISO 37001 are numerous. It can be used as the foundation in the establishment or improvement of an anti-bribery management system. It can be used as the criteria to evaluate where an organization aligns, in relation to global best practices used by other organizations. The standard serves as a tool to provide clarity, and to demonstrate to the organization’s stakeholders, including its Board of Directors, its personnel, its business partners and its investors, on its position against bribery. Lastly, Implementing ISO 37001 helps to ensure adherence with applicable law.

Adopting the ISO 37001 standard establishes a formal program designed to prevent bribery, which is documented, audited and readily available to authorities for review. It also clearly demonstrates to employees the company’s position against bribery, so that it becomes part of the organization’s DNA.

Building an effective Anti-bribery Management System (ABMS) requires expertise in Compliance, work experience in a corporate environment, understanding the governance of an organization and knowledge of the basics of a management system. The first three elements are based on relevant work experience. The last element can be obtained through training.

The most efficient and effective approach is to have the future architects of your ABMS (employees in your organization) receive specialized training on implementation of the ISO 37001 standard. STEER LLC is certified through PECB, a globally accredited certification body, to provide your key employees with training that will, upon completion, provide them with an internationally recognized certification designating them as PECB certified ISO 37001 Lead Implementers. The training is presented in a 4-day classroom setting, followed by an exam on day 5.

In light of the global coronavirus restrictions currently affecting business travel and gatherings, STEER also offers web based training where our instructor presents the training course live, and therefore can be available to the attendees to answer questions and provide support.

Lastly, this training provides a solid foundation for understanding how to meet all the requirements of this ISO standard and master concepts, approaches, methods and techniques used for implementation and effective management of an ABMS. Participants learn to interpret the standard’s requirements in the specific context of an organization, and how to support an organization to effectively plan, implement, manage, monitor and maintain an ABMS

The 3 partners from STEER LLC, your trainers, have over 90 years of combined relevant international work experience in corporate bribery prevention, compliance, audit and risk management, having held Senior Management positions at multinational companies. Read more about us on

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