Section 7 of the Bribery Act 2010 creates strict corporate liability — if anyone associated with your firm bribes someone to obtain business, your firm commits a criminal offence. The penalty is unlimited. The only statutory defence is proving you had adequate procedures in place. The FCA adds a further layer: SYSC 6.1.1R requires firms to have effective systems and controls to counter bribery risk, and a finding of inadequate ABC procedures is simultaneously a criminal exposure and a regulatory governance failure. Your firm can be criminally liable for bribery you didn't know about.
What's included:
Full legal framework: Bribery Act 2010 Sections 1–7, MoJ six principles, FCA SYSC 6.1.1R, FCG 6.3, OFSI sanctions integration, FCPA, OECD, and UNCAC — with enforcement context (unlimited fines, 10 years' imprisonment, and FCA permissions restrictions)
Gifts and hospitality policy: four-tier approval thresholds (£50/£250/£500/£500+) with cumulative annual tracking, red flag indicator library, and Gifts and Hospitality Register template
Third-party management: pre-engagement due diligence, mandatory contractual ABC clauses, ongoing monitoring, and termination provisions for non-compliance — with sanctions and bribery intersection framework (OFSI, FATF, Transparency International, and World Bank)
Customer and counterparty due diligence: PEP matrix, state-owned enterprise assessment, and high-risk sector identification
Investigation protocol: 35-day three-phase framework — with disciplinary matrix from verbal warning through to criminal referral and four-channel reporting structure with response time SLAs
Whistleblowing protection: PIDA 1998 and SYSC 18 integration with three-lines-of-defence monitoring model and quarterly effectiveness testing programme
Five ready-to-use templates: risk assessment, third-party due diligence checklist, gifts register, training log, and incident reporting form
+ much more
Who is this for?
Compliance Officers, MLROs, Boards, and senior managers at FCA-regulated firms who need a complete, board-approved Bribery Act-compliant ABC framework with full SM&CR accountability integration — and a documented Section 7 statutory defence.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
Section 7 of the Bribery Act 2010 creates strict corporate liability — if anyone associated with your firm bribes someone to obtain business, your firm commits a criminal offence. The penalty is unlimited. The only statutory defence is proving you had adequate procedures in place. The FCA adds a further layer: SYSC 6.1.1R requires firms to have effective systems and controls to counter bribery risk, and a finding of inadequate ABC procedures is simultaneously a criminal exposure and a regulatory governance failure. Your firm can be criminally liable for bribery you didn't know about.
What's included:
Full legal framework: Bribery Act 2010 Sections 1–7, MoJ six principles, FCA SYSC 6.1.1R, FCG 6.3, OFSI sanctions integration, FCPA, OECD, and UNCAC — with enforcement context (unlimited fines, 10 years' imprisonment, and FCA permissions restrictions)
Gifts and hospitality policy: four-tier approval thresholds (£50/£250/£500/£500+) with cumulative annual tracking, red flag indicator library, and Gifts and Hospitality Register template
Third-party management: pre-engagement due diligence, mandatory contractual ABC clauses, ongoing monitoring, and termination provisions for non-compliance — with sanctions and bribery intersection framework (OFSI, FATF, Transparency International, and World Bank)
Customer and counterparty due diligence: PEP matrix, state-owned enterprise assessment, and high-risk sector identification
Investigation protocol: 35-day three-phase framework — with disciplinary matrix from verbal warning through to criminal referral and four-channel reporting structure with response time SLAs
Whistleblowing protection: PIDA 1998 and SYSC 18 integration with three-lines-of-defence monitoring model and quarterly effectiveness testing programme
Five ready-to-use templates: risk assessment, third-party due diligence checklist, gifts register, training log, and incident reporting form
+ much more
Who is this for?
Compliance Officers, MLROs, Boards, and senior managers at FCA-regulated firms who need a complete, board-approved Bribery Act-compliant ABC framework with full SM&CR accountability integration — and a documented Section 7 statutory defence.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
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