In part 1, we discussed how ISO 37001 ABMS can help companies across a wide range of industries, including automotive, aviation and insurance. In part 2, we looked at how pharma and healthcare, property, IT and telecommunications organisations can benefit from Anti-Bribery solutions as well. In this final part, we will explore some aspects of how companies from the financial, oil and energy industries could implement ABAC solutions.


Bribery and corruption are among the top fraud concerns for all financial organisations. These include banks & financial institutions, real estate lenders, business credit and finance companies, commercial investment corporations, asset-based lenders, debt financing firms, acquisition capital firms and others. Having safeguarding processes in place is required both from a legal and compliance standpoint and from the position of being a trusted, secure financial institution. The financial sector includes new Anti-Money Laundering (AML) rules and legislation, and these regulations are strict and increasingly enforced. As such, remaining in compliance through implementing proper prevention controls is a must.

In one high-profile case, between 2006 and 2013, JPMorgan Chase and its subsidiary, JP Morgan Securities (Asia Pacific) Limited (JPM-APAC) took on about 100 Chinese interns and full-time employees who ended up at the centre of a bribery case spread over two continents and worth hundreds of millions of dollars. In order to win business from members of the Chinese government and state-owned companies, JPM-APAC allegedly targeted their children, offering them high-ranking and well-paid positions in the business in order to curry favour with their parents. JP Morgan fell into trouble for allegedly violating the Foreign Corrupt Practices Act (FCPA), and the DoJ called the scheme ‘bribery by any other name’ – alleging that it had threatened national security. In November 2016, the bank was ordered to pay $264 million to settle the claims against it – $130m to the SEC for violations of the FCPA, $72m to the US Justice Department and $61.9m to the Federal Reserve Board of Governors.

CRI Group™ investigates: Pharma corruption case included CFO

ISO 37001 in Oil, Gas and Energy Industries

The oil and energy sector is a massive portion of the world’s economy, dealing mainly in petroleum – including upstream (exploration, development and production of crude oil or natural gas) and downstream (oil tankers, refiners, retailers and consumers) pipeline. The need to prospect, discover, and realise oil and energy production in various (and often far-flung) locations lends to the vulnerability to fraud – but geographic considerations aren’t the only risk factors.  Perhaps even more impactful is the complexity of business relationships required to operate in the industry – relationships with governments, contractors, regulators, investors/venture partners, equipment suppliers and other parties. Every such interaction and dealing can be considered susceptible to bribery and corruption where cutting corners may be considered profitable or even perceived to be “business as usual.”

An infamous example is the case of Petrobras. In December 2017, the world’s largest builder of offshore rigs agreed to pay $422 million in penalties after entering a guilty plea for bribery charges connected with the Petroleo Brasileiro (Petrobras) scandal. Keppel Offshore & Marine Ltd. made illicit payments to both Petrobras officials and government representatives for more than a decade, between 2001 and 2014 (Reuters, 2017). The sweeping multimillion-dollar bribery scandal that rocked Petrobras led to numerous investor lawsuits and the downfall of disgraced government officials. It also served as the embodiment of the huge risk of bribery and corruption that confronts the entire oil and energy sector. See “Oil and Energy Companies Look to ISO 37001.”

Long-lasting Benefits of Certification of ISO 37001

ISO 37001 provides a strong framework for addressing and isolating risk factors in all industries. The benefits of certification are far-reaching, impacting not just the primary organisation but also influencing contractors, clients, and raising the profile of the company as an ethical entity that is a good trading partner. Even more effective, ABAC™ tailors IS0 37001 to the specific needs of the client.

By achieving ISO 37001:2016 certification, an organisation will ensure that it is implementing a viable anti-bribery management system utilising widely accepted controls and systems. It will also assure management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. Today, companies cannot afford to be reactive to threats of bribery and corruption. By achieving ISO 37001 Anti-Bribery Management System certification today, an organisation will remain in compliance and better positioned to address risks head-on.

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Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.