On 30 September 2021, UK Finance published Anti-Bribery and Corruption Compliance – Definition of public officials. The purpose of the paper is to establish practical and risk-based guidance on the definition of public officials for the purposes of anti-bribery and corruption (ABC) compliance.
The paper has been written with a UK legislative lens but is not limited to public officials in the UK, and also considers complementary global ABC legislation to inform the guidance. This includes consideration of anti-money laundering and counter-terrorist financing (AML/CFT) definitions of ‘politically exposed persons’, but the paper does not provide guidance for these separate requirements. The paper also sets out a recommended approach to this definition and illustrative guidance of specific examples for inclusion and exclusion, to help firms with setting their individual ABC risk appetites for identifying and dealing with public officials. It also seeks to input to future updates of existing definitions (e.g. Wolfsberg Group – Anti-Bribery and Corruption Compliance Programme Guidance 2017).