How to Put Together and Maintain an Effective Anti-Birbery and Corruption Compliance Program

It's a comprehensive document about how to put together and maintain an effective anti-bribery and corruption compliance program at the institutional level. One of the things that caught my eye as I was looking at it is these kinds of programs with various different titles, ethics program or code of conduct but they've been around in certainly decent sized banks in the US for a long time. And latest piece I think does a really nice job of laying out what you ought to consider and the kinds of things that ought to go into it.