Anti-Bribery and Corruption Compliance Training Course

Duration 5 days 10 modules · 33 contact hours
Level Intermediate Certificate on completion
Who attends Compliance Managers, Finance Managers and others
Fee from USD 1,100 KSh 95,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 7 Nov 2026 Course code SD-FFC-011

Before you join: Participants should understand basic business processes such as purchasing, supplier payment, expense claims, sales contracting or internal approval workflows.

Dates & prices

Two start dates a month in every city, and live online on weekdays or weekends. Fees are per participant; classroom fees include tuition, materials, lunch and refreshments, and the certificate.

Suggest a date or city

Showing the next six months. Later dates, other cities and private deliveries for your team are available on request.

Course overview

Bribery and corruption risk rarely appears as a single obvious payment. It can sit in an agent’s commission, a donation linked to a permit, hospitality offered during a tender, or an invoice that hides an improper benefit. Finance, procurement, sales and compliance staff must distinguish legitimate commercial activity from conduct that creates criminal, regulatory, contractual and reputational exposure. They also need controls that stand up to scrutiny when business pressure, public officials or opaque third parties are involved.

This five-day course examines the laws, standards, risk methods and financial controls used to prevent, detect and respond to bribery and corruption. Participants assess exposure using risk registers and heat maps; build proportionate third-party due diligence; test gifts, hospitality, charitable donations and sponsorships; and identify accounting entries that may conceal improper payments. The course also covers whistleblowing, internal investigations, corrective action, training, monitoring and board reporting. Reference points include ISO 37001, the UK Bribery Act and Foreign Corrupt Practices Act requirements.

Teaching combines focused instructor briefings with sector-based cases involving procurement, public contracting, international sales, banking relationships and intermediary management. Participants work through control decisions, review red flags, interpret payment data and prepare documented responses to allegations. They leave with a practical anti-bribery compliance toolkit, including a risk assessment model, third-party due diligence checklist, gifts and hospitality register, investigation plan and 90-day improvement plan.

The course suits professionals who own, operate, test or oversee anti-bribery controls, including compliance, finance, procurement, internal audit, legal and commercial teams.

What you will be able to do

  • Assess bribery and corruption exposure using an ISO 37001-aligned risk assessment
  • Design proportionate third-party due diligence and ongoing monitoring procedures
  • Apply gifts, hospitality, donations and sponsorship approval controls
  • Identify financial red flags through invoice, payment and ledger analysis
  • Build anti-bribery policies, accountability matrices and escalation routes
  • Plan allegation triage, evidence preservation and internal investigation activities
  • Develop corrective action plans using root-cause analysis and effectiveness testing
  • Prepare management information and a 90-day anti-bribery improvement plan

Benefits of attending

For you

  • Recognise bribery indicators hidden in commercial arrangements and financial records
  • Make documented approval and escalation decisions under commercial pressure
  • Conduct proportionate third-party due diligence using defined risk criteria
  • Contribute effectively to allegation triage and internal investigation planning
  • Present anti-bribery risks and control actions clearly to senior management

For your organisation

  • More consistent assessment of bribery exposure across markets, transactions and third parties
  • Stronger controls over agents, distributors, consultants and joint ventures
  • Earlier detection of suspicious payments, expenses and accounting entries
  • Better documented responses to allegations, investigations and remediation actions
  • Clearer board assurance through risk indicators, monitoring and control reporting

Course modules

10 modules over 5 days

Participants can distinguish bribery risks and explain the legal and organisational consequences of improper conduct.

  • Bribery, corruption and facilitation payments distinguished through legal and business examples
  • FCPA, UK Bribery Act and local law jurisdictional reach
  • Corporate and individual liability arising from improper offers, promises and payments
  • Public officials, state-owned entities and commercial counterparties classified by risk
  • Intent, knowledge and willful blindness assessed from evidence patterns
  • Books-and-records offences linked to false descriptions and concealed transactions
  • Enforcement actions analysed for control failures, penalties and remediation

Participants can define governance arrangements, accountabilities and reporting lines for an anti-bribery programme.

  • ISO 37001 anti-bribery management system requirements mapped to control ownership
  • Tone from the top translated into measurable conduct expectations
  • Three lines model assigned across business, compliance and internal audit
  • Risk appetite statements distinguish prohibited conduct from managed exposure
  • Policies, procedures and controls aligned through a documented compliance framework
  • Board reporting uses key risk indicators and control assurance evidence
  • Accountability matrices identify decision rights, escalation routes and approval limits

Participants can conduct and document a risk-based assessment of bribery and corruption exposure.

  • ISO 37001 risk assessment criteria calibrated for bribery exposure
  • Country, sector, transaction and relationship risks scored using heat maps
  • Inherent and residual risk separated through control-effectiveness testing
  • Risk registers record causes, controls, owners, actions and review dates
  • Data sources include enforcement records, payment data and employee interviews
  • Risk-based prioritisation directs monitoring resources toward material exposure
  • Documenting assessment rationale supports challenge, approval and periodic refreshes

Participants can apply risk-based due diligence and contractual controls to third-party relationships.

  • Third-party lifecycle controls address agents, distributors, consultants and joint ventures
  • Due diligence tiers set screening depth from risk scoring
  • Beneficial ownership, sanctions, adverse media and reputation checks documented
  • Red flags tested through invoices, references, payment terms and ownership
  • Contract clauses specify audit rights, certification, termination and training
  • Approval workflows prevent business sponsors bypassing due diligence requirements
  • Post-onboarding monitoring detects changed ownership, allegations and unusual payments

Participants can apply proportionate approval and recordkeeping controls to high-risk expenditure.

  • Gift, hospitality, travel, donations and sponsorship categories defined clearly
  • Thresholds and pre-approval rules calibrated against recipient and context
  • Government official interactions require heightened review and documented business purpose
  • Charitable donations screened for beneficiary legitimacy and diversion indicators
  • Sponsorship agreements test fair value, deliverables and recipient connections
  • Registers capture value, attendees, purpose, approvals and supporting evidence
  • Facilitation payment requests handled through refusal, escalation and safety protocols

Participants can identify financial control weaknesses and analyse payment patterns for bribery indicators.

  • Segregation of duties prevents initiation, approval and payment concentration
  • Three-way matching tests purchase orders, receipts and supplier invoices
  • General ledger analytics identify round sums, duplicates and unusual accounts
  • Payment controls validate bank changes, beneficiaries and supporting documentation
  • Petty cash and expense claims tested against policy and evidence
  • Journal entries reviewed for management override and concealed disbursements
  • Data analytics scenarios target high-risk vendors, countries and account codes

Participants can plan a fair, controlled response to suspected bribery or corruption allegations.

  • Speak-up channels designed for confidentiality, accessibility and non-retaliation protection
  • Allegation triage assesses credibility, urgency, scope and preservation needs
  • Investigation plans define allegations, witnesses, evidence sources and milestones
  • Chain-of-custody logs preserve documents, devices and interview records
  • PEACE interviewing structure supports fair, focused witness and subject interviews
  • Investigation reports separate facts, findings, root causes and recommendations
  • Disclosure decisions consider legal advice, regulators and contractual obligations

Participants can develop corrective actions that address misconduct, control failure and repeat risk.

  • Root-cause analysis distinguishes individual misconduct from system control failure
  • Five Whys identifies process breakdowns behind repeated policy breaches
  • Corrective action plans assign owners, deadlines, evidence and effectiveness tests
  • Disciplinary decisions apply consistent criteria, documented rationale and legal review
  • Control remediation addresses policy gaps, supervision, systems and incentives
  • Lessons learned updates risk assessments, training content and monitoring plans
  • Regulator-facing remediation evidence demonstrates timely action and sustained oversight

Participants can plan targeted communications and training that reinforce expected anti-bribery behaviour.

  • Role-based training maps bribery risks to decisions employees actually make
  • Scenario design tests refusal, escalation and documentation under commercial pressure
  • Manager briefings reinforce accountability for approvals and third-party oversight
  • Communications plans sequence policy launches, reminders and leadership messages
  • Training records evidence attendance, assessment results and overdue follow-up
  • Culture indicators combine speak-up data, surveys and conduct trends
  • Performance incentives reviewed for sales pressure and misconduct inducements

Participants can monitor anti-bribery controls and prioritise practical programme improvements.

  • Compliance monitoring plan links tests to risk ratings and controls
  • Key risk indicators track exceptions, overdue diligence and approval breaches
  • Internal audit scopes independent assurance over anti-bribery control design
  • Management information distinguishes incidents, allegations, investigations and confirmed cases
  • Dashboard reporting presents trends, root causes, actions and ownership
  • Annual programme review tests ISO 37001 alignment and improvement priorities
  • Personal application plans schedule first 90-day control improvements

Exercises and examples are adapted to each cohort's sectors and roles.

What you take back to work

  1. ISO 37001-aligned bribery risk assessment template
  2. Third-party due diligence checklist
  3. Gifts, hospitality and sponsorship register
  4. Financial red-flag review checklist
  5. Allegation triage and investigation plan
  6. 90-day anti-bribery improvement plan

Who should attend

  • Compliance Managers — responsible for designing and maintaining anti-bribery programmes
  • Finance Managers — responsible for payment controls, accounting integrity and expense oversight
  • Procurement Managers — responsible for supplier selection, contracting and intermediary controls
  • Internal Auditors — responsible for testing anti-bribery control design and operating effectiveness
  • Legal Counsel — responsible for advising on allegations, investigations and disclosure decisions
  • Sales and Commercial Managers — responsible for managing agents, distributors and public-sector interactions

Skills and tools covered

Bribery risk assessmentThird-party due diligenceFinancial red-flag detectionInvestigation planningControl remediationCompliance reporting

Tools and standards

ISO 37001 Anti-bribery Management Systems, UK Bribery Act 2010, US Foreign Corrupt Practices Act, COSO Fraud Risk Management Guide

How the course runs

Training methodology

The course uses short instructor briefings to establish legal duties, ISO 37001 requirements and control methods. Participants analyse realistic cases involving agents, public officials, tender activity, donations, sponsorships and suspicious invoices. Group work applies risk scoring, due diligence decisions, payment-control testing and allegation triage. Simulations focus on refusal conversations, escalation decisions and investigation planning. Participants finish by translating course methods into a prioritised 90-day plan for their own role or organisation.

Requirements and prerequisites

Participants should understand basic business processes such as purchasing, supplier payment, expense claims, sales contracting or internal approval workflows. Experience in compliance, finance, procurement, audit, legal, risk or commercial operations is useful, particularly where third parties or public-sector customers are involved. Participants should be comfortable reading policies, invoices, contracts and management reports. Prior knowledge of the UK Bribery Act, Foreign Corrupt Practices Act, ISO 37001 or forensic investigation methods is not required. This is not a legal qualification course and does not require accounting certification.

A typical training day

08:30 – 10:30First session
10:30 – 10:45Refreshment break
10:45 – 12:30Second session
12:30 – 13:30Lunch and networking
13:30 – 15:00Third session
15:00 – 15:15Refreshment break
15:15 – 16:30Workshop and daily review

Live online deliveries follow the same structure in East Africa Time, with shorter screen blocks and longer breaks.

What the fee includes

  • Instruction by a practitioner facilitator
  • Full course workbook and materials
  • Exercise files, templates and case studies
  • Refreshments and lunch on classroom deliveries
  • Certificate of completion
  • Post-course application plan

Frequently asked questions

You should understand basic business processes such as procurement, payments, expense approval, contracting or audit. No prior study of anti-bribery law, ISO 37001 or forensic investigation is required.

Bring a laptop if possible, along with any non-confidential policies, approval processes or control questions relevant to your role. Course materials and case documentation are provided.

It is designed for professionals in compliance, finance, procurement, internal audit, legal, risk and commercial management. It is particularly relevant to staff managing intermediaries, public-sector business, supplier relationships or high-risk payments.

This course focuses on preventing, detecting and responding to bribery and corruption, including third parties, improper benefits and related accounting controls. Fraud investigation courses place greater emphasis on evidence gathering and case investigation, while sanctions training addresses restricted parties and prohibited jurisdictions.

Participants can use the risk assessment, due diligence, register and monitoring templates to review current controls. The 90-day plan helps convert identified gaps into assigned actions, deadlines and evidence requirements.

The course contains ten modules delivered in teaching order, with approximately 6.5 contact hours each day from 08:30 to 16:30. Time is divided between instructor input, case analysis, group application, simulations and individual planning.

Questions about this course?

Ask about dates, fees, group bookings or running it for your team. Our training team replies by email.

Ask on WhatsApp info@skillsetdevelopment.com

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