Anti-Bribery and International Compliance Training Course

Duration 5 days 10 modules · 33 contact hours
Level Intermediate Certificate on completion
Who attends Compliance Managers, Legal Counsel and others
Fee from USD 1,100 KSh 95,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 16 Nov 2026 Course code SD-L-065

Before you join: Participants should have working experience in compliance, legal, audit, finance, procurement, risk management or a related control function.

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 risks often arise through ordinary commercial activity: engaging an agent, hosting a public official, bidding for a licence, approving a donation, or paying an invoice with weak supporting evidence. Organisations operating across borders must meet overlapping legal duties while maintaining practical controls that employees can apply under commercial pressure. Failures can lead to criminal investigations, civil penalties, debarment, lost contracts, management disruption and personal liability for decision-makers.

This course examines the legal principles, compliance standards and control methods used to prevent, detect and respond to bribery and corruption risks. Participants compare key requirements under the U.S. Foreign Corrupt Practices Act, UK Bribery Act 2010 and OECD Anti-Bribery Convention; conduct risk-based assessments; assess gifts, hospitality, donations and sponsorships; and manage third-party exposure. The programme also addresses payment controls, books-and-records risks, internal reporting, investigations, remediation, monitoring and board reporting. Participants learn to distinguish acceptable business conduct from improper influence and to document decisions that may later face scrutiny.

Teaching combines instructor briefings with realistic cases involving procurement, public-sector contracting, banking intermediaries, humanitarian programmes and multinational supply chains. Participants work through risk assessments, due diligence findings, payment anomalies, investigation decisions and corrective-action priorities. They leave with a practical anti-bribery compliance toolkit containing reusable templates, decision criteria and an application plan for their own responsibilities. The course suits professionals who own, oversee or support anti-bribery controls and need a structured method for making defensible compliance decisions.

What you will be able to do

  • Interpret FCPA, UK Bribery Act and OECD Convention obligations in business scenarios
  • Conduct a risk-based bribery risk assessment using ISO 37001 inputs
  • Design policy and approval controls for gifts, hospitality and charitable contributions
  • Perform third-party due diligence and document risk-based engagement decisions
  • Test payment and accounting controls against corruption red flags
  • Plan legally defensible internal investigations, evidence preservation and escalation
  • Create remediation and monitoring plans with accountable owners and measurable indicators
  • Apply escalation protocols and record defensible anti-bribery decisions

Benefits of attending

For you

  • Make and document defensible decisions on gifts, hospitality and third-party engagements
  • Recognise bribery red flags before approving high-risk transactions
  • Contribute effectively to internal investigations and evidence-preservation actions
  • Apply structured risk assessment methods to anti-bribery programme priorities
  • Communicate material corruption concerns clearly to management and legal advisers

For your organisation

  • More consistent anti-bribery decisions across procurement, finance and commercial teams
  • Earlier identification of risky agents, payments and government-facing transactions
  • Stronger evidence of risk-based controls and management oversight
  • Better prepared investigation, remediation and escalation processes
  • Reduced exposure to enforcement action, contractual exclusion and reputational damage

Course modules

10 modules over 5 days

Participants can identify bribery risks, applicable legal duties and potential corporate or individual liability.

  • Bribery, facilitation payments, kickbacks and improper advantages distinguished using legal tests
  • Public official, state-owned enterprise and commercial bribery risk categories
  • Corporate liability, individual liability and extraterritorial jurisdiction under major anti-bribery laws
  • FCPA, UK Bribery Act and OECD Convention compared
  • Books-and-records offences linked to concealed corrupt payments
  • Enforcement actions analysed for misconduct patterns and control failures

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

  • ISO 37001 risk assessment inputs: country, sector, transaction and counterparties
  • Risk scoring matrices calibrated with likelihood, impact and control effectiveness
  • Country risk indicators tested against transaction-specific red flags
  • Third-party, government-touchpoint and payment-channel exposure mapped across business processes
  • Documenting risk rationale, sources, owners and review dates
  • Residual-risk decisions aligned with risk appetite and escalation thresholds

Participants can translate anti-bribery requirements into accountable governance and policy controls.

  • Anti-bribery policy clauses: prohibited conduct, approvals, reporting and sanctions
  • Tone from the top translated into accountable management actions
  • Delegated authority matrices matched to expenditure and engagement risks
  • Control owners assigned through RACI responsibility mapping and evidence registers
  • Local procedures reconciled with global minimum control requirements
  • Policy exceptions recorded, approved and periodically reassessed by compliance

Participants can assess and control common business expenditure with bribery exposure.

  • Gift, hospitality, travel and entertainment assessed against proportionality criteria
  • Pre-approval thresholds designed around recipient status, value and purpose
  • Registers capture business rationale, attendees, values and approval evidence
  • Government official invitations screened for official purpose and timing
  • Charitable donations tested for beneficiary legitimacy and improper influence
  • Sponsorship agreements specify deliverables, payment controls and conflicts disclosures
  • Facilitation-payment requests handled through safety, recording and escalation protocols

Participants can perform risk-based due diligence and establish appropriate third-party controls.

  • Risk-based due diligence tiers defined for agents, distributors and consultants
  • Beneficial ownership, sanctions and adverse-media screening documented before engagement
  • Questionnaires test qualifications, government connections, compensation and subcontracting arrangements
  • Contract clauses require audit rights, certifications and termination triggers
  • Compensation benchmarks identify excessive commissions and vague service descriptions
  • Ongoing monitoring uses invoice testing, renewals and changed-risk events

Participants can identify control weaknesses and corruption indicators in high-risk transactions.

  • Payment controls link invoices, contracts, approvals and proof of service
  • Segregation of duties prevents single-person initiation, approval and release
  • Offshore accounts, cash requests and split invoices identified as red flags
  • Accounts payable testing traces high-risk payments to supporting evidence
  • Acquisition due diligence assesses inherited corruption liabilities and remediation needs
  • Joint-venture governance allocates compliance responsibilities, audit rights and reporting

Participants can plan a proportionate response to suspected bribery or control failures.

  • Speak-up channels designed for confidentiality, accessibility and non-retaliation
  • Intake triage assesses allegation credibility, urgency, jurisdiction and preservation needs
  • Investigation plans define scope, privilege, witnesses, evidence and timelines
  • Document preservation notices prevent deletion of relevant electronic records
  • Interview sequencing separates fact gathering from credibility assessment
  • Findings reports distinguish substantiated allegations, root causes and corrective actions

Participants can develop corrective actions following confirmed or suspected misconduct.

  • Root-cause analysis uses five whys, control mapping and conduct evidence
  • Corrective action plans assign owners, deadlines, metrics and closure evidence
  • Disciplinary processes apply consistently across seniority, geography and employment status
  • Voluntary disclosure factors assessed with counsel under applicable enforcement policies
  • Remediation testing verifies that revised controls operate as designed
  • Board reporting presents significant risks, investigations, actions and decisions

Participants can establish monitoring and testing activities that support programme improvement.

  • Compliance monitoring plans prioritise high-risk markets, processes and third parties
  • Key risk indicators track approvals, exceptions, gifts and investigation trends
  • Sample testing selects transactions using risk-based population criteria
  • Internal audit coordination distinguishes assurance work from compliance monitoring
  • Management information packs combine leading indicators with control-failure evidence
  • ISO 37001 performance evaluation supports periodic programme improvement

Participants can apply escalation, documentation and control methods to their own responsibilities.

  • Personal responsibility mapped to approval, escalation and reporting decisions
  • Scenario analysis applies red flags to tendering, licensing and procurement
  • Decision logs record rationale, evidence, approvers and unresolved concerns
  • Escalation communications state facts, risk, urgency and requested action
  • Thirty-day application plans target controls requiring immediate improvement
  • Peer review refines action plans against organisational constraints and accountabilities

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 donations approval matrix
  4. Anti-bribery red-flag payment review checklist
  5. Internal investigation planning template
  6. Thirty-day anti-bribery control action plan

Who should attend

  • Compliance Managers — responsible for anti-bribery programme design and oversight
  • Legal Counsel — advising on corruption exposure, investigations and legal obligations
  • Internal Auditors — testing control design and operating effectiveness
  • Procurement Managers — managing supplier, agent and intermediary engagement risks
  • Finance Controllers — overseeing payment controls, records and exception management
  • Risk Managers — assessing enterprise corruption exposure and reporting significant risks

Skills and tools covered

Bribery risk assessmentThird-party due diligenceAnti-bribery controlsInvestigation planningCompliance monitoringEscalation decisions

Tools and standards

ISO 37001 Anti-bribery Management Systems, U.S. Foreign Corrupt Practices Act, UK Bribery Act 2010, OECD Anti-Bribery Convention

How the course runs

Training methodology

The course uses short instructor briefings to establish legal duties, standards and control principles, followed by case work based on agent appointments, tendering, charitable funding, public-official contact and suspect payments. Small-group analysis applies risk matrices, due diligence criteria, approval rules and investigation planning methods. Simulations focus on escalation conversations, evidence decisions and management reporting. Participants consolidate learning through structured application planning tied to their own policies, controls and decision rights.

Requirements and prerequisites

Participants should have working experience in compliance, legal, audit, finance, procurement, risk management or a related control function. Familiarity with internal policies, approval processes, third-party engagement or financial controls is useful. Participants should be comfortable reading policy extracts, reviewing business records and discussing realistic commercial scenarios. Prior study of anti-bribery law, formal legal training, investigation experience or ISO 37001 certification is not required. The course explains legal concepts in operational terms but assumes participants can relate them to their own organisational responsibilities.

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

Participants need practical familiarity with a business control function such as compliance, legal, audit, finance, procurement or risk. No legal qualification, previous anti-bribery course or ISO 37001 certification is required.

Participants should bring examples of their organisation's anti-bribery policy, gifts rules, due diligence process or approval procedures where permitted. Confidential documents are not required, and cases can be discussed using anonymised facts.

The course is designed for professionals who make, review or oversee decisions with bribery exposure. It is particularly relevant to compliance, legal, internal audit, procurement, finance, risk and commercial management roles.

This course focuses specifically on anti-bribery laws, corruption controls and decisions that create legal exposure. It examines operational topics such as intermediaries, public officials, payments, investigations and remediation rather than general workplace conduct.

Participants receive reusable assessment, due diligence, approval and investigation tools that can be adapted to internal procedures. The final module produces a focused application plan for strengthening a control, decision process or reporting route.

Training runs from 08:30 to 16:30 each day, providing about 6.5 contact hours daily. The five days cover ten teaching modules through briefings, case analysis, group work, simulations and application planning.

Questions about this course?

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