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A. General Principles

1. VASPs shall establish and maintain an effective anti-bribery and corruption policy to ensure that the Board and all Staff must comply with all applicable laws and regulations relevant to anti-bribery and corruption in all jurisdictions in which they operate. Such policy must allow for reports to be made by Entities outside of the VASP and protect the identity and confidentiality of the Entity who has made a report at all times.
2. VASPs must conduct all business in an honest and ethical manner and must take a zero-tolerance approach to bribery and corruption. The Board and all Staff must act professionally, fairly and with integrity in all business dealings and relationships.
3. It is prohibited for any VASP, members of the Board and all Staff, to—
 
  a. give, promise to give, or offer, a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received or to reward a business advantage already given;
  b. give, promise to give, or offer, a payment, gift or hospitality to a third party to facilitate or expedite a routine procedure;
  c. accept a payment, gift or hospitality from a third party if it knows or suspects that such payment, gift or hospitality is offered or provided with an expectation that a business advantage will be provided by the VASP in return;
  d. threaten or retaliate against another member of the Board or Staff who has refused to commit a bribery offence or who has raised concerns; and
  e. engage in any activity that might lead to a breach of the anti-bribery and corruption Rules in this Part VI of this Compliance and Risk Management Rulebook.
 
4. The anti-bribery and corruption Rules in this Part VI of this Compliance and Risk Management Rulebook do not prohibit normal and appropriate hospitality [given or received in accordance with the VASP’s own gifts and hospitality policy] to or from third parties, provided relevant policies are compliant with applicable laws. Such gifts and hospitality policy should set out clearly what is and is not appropriate to make or receive gifts and/or hospitality to and from a third party.
5. The CO will monitor the effectiveness of the anti-bribery and corruption policy on a regular basis. Any deficiencies identified should be dealt with as soon as possible.