Bribery Act: Advanced Monitoring Techniques

Curiously, part of the challenge when implementing procedures to prevent bribery is in fact not really to do with prevention at all, but detection. In Principle 6 of its draft guidance on adequate procedures, the Ministry of Justice discusses the internal monitoring and review mechanisms that companies may consider implementing with a view to ensuring that their anti-bribery policies are effective.

Organisations may conclude that they can satisfactorily monitor for bribery simply through a combination of whistle-blowing policies and a programme of periodic on-site reviews. However, while both approaches can play an important role in the detection process, both also have weaknesses which indicate that additional techniques may need to be adopted.

One answer to the question of how to detect bribery lies in a set of technologies and techniques known as Transaction Monitoring, which can minimise the human role in the detection of suspicious activity, and instead focus it where it has most impact – the evaluation and investigation of that activity. By deploying a Transaction Monitoring solution, companies can achieve some significant benefits in terms of coverage; immediacy; objectivity; and reliability.

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