We recently wrote about ongoing assessments as a key component of a best practices anti-corruption and anti-bribery program. One of our colleagues commented that such a tool is also one with which a company should begin to craft its compliance program. The simple reason is straightforward; one cannot define, plan for, or design an effective compliance program to prevent bribery and corruption unless you can measure the risks you face. Therefore this post will discuss the tool that an entity should utilize to build its anti-corruption and anti-bribery program around, the Risk Assessment.

We believe that for this reason both the Principles of Federal Prosecution of Business Organization (US Sentencing Guidelines) and its section on corporate compliance programs and the UK Bribery Act’s Consultative Guidance list Risk Assessment as the initial step in creating an effective anti-corruption and anti-bribery program. This posting will review the specifics of an effective Risk Assessment and how it will form the development, implementation and maintenance of any best practices compliance program.