Anti-bribery & corruption controls for account opening

For compliance teams, the practical implication is to revisit account opening policies, customer risk assessments and escalation routes so that ABC red flags are identified consistently alongside money laundering and sanctions risks. Firms should expect scrutiny of how source of funds and source of wealth are evidenced, how higher-risk customers and intermediaries are escalated, and how frontline staff document decisions. Executive sponsors should confirm that governance, training and quality assurance cover bribery and corruption risks in customer onboarding, including third-party introducers, referral arrangements and gifts or hospitality.

Action points include updating risk-based onboarding procedures, strengthening enhanced due diligence for higher-risk relationships, reviewing introducer and outsourcing due diligence, refreshing frontline training, and testing whether existing monitoring and exception reporting capture ABC concerns. Firms should also retain clear audit trails of approvals and exceptions. The change is unlikely to require a standalone programme for most institutions, but it may require cross-functional alignment between financial crime, onboarding operations, legal and business teams.

Institutions with complex corporate, wealth or cross-border onboarding flows should prioritise a gap assessment and remediation plan, while smaller firms should focus on proportionate policy updates and staff awareness. Overall, the direction supports stronger customer trust and more defensible regulatory outcomes, but firms that treat ABC as separate from AML/CFT onboarding may face supervisory challenge.