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CFCS (Other exams): Corruption, Sanctions and Asset Recovery

CFCS · Work through your exam, one topic at a time.

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Corruption, Sanctions and Asset Recovery

Corruption

Bribery is offering, promising or giving an advantage to influence official action; kickbacks and facilitation payments are variants. Know the FCPA (anti-bribery provisions, accounting provisions, narrow facilitation-payment exception) and the UK Bribery Act (broad commercial and foreign-public-official coverage, strict liability for failure to prevent bribery, no facilitation-payment exception). PEPs, gifts and hospitality registers, third-party and agent due diligence, and red flags such as unusual commissions or offshore intermediaries are core.

Sanctions

Sanctions are preventive restrictions, not criminal convictions. Understand primary vs secondary sanctions, designated persons and entities (SDN-style lists), the 50% ownership rule (entities owned 50% or more in aggregate by blocked persons are themselves blocked), sectoral sanctions, screening, asset freezing, licenses, and evasion typologies. Strict liability means no intent is required to breach.

Asset recovery

Recovery follows trace, freeze, confiscate, repatriate. Tools include mutual legal assistance, non-conviction-based forfeiture, and UNCAC chapter V. Kleptocracy cases often combine corruption and sanctions.

Worked example

A company is 45% owned by one SDN and 10% by another. Aggregate ownership is 55%, so the company is blocked. A license is needed before dealing. The wrong answer is "each holding is under 50%, so it's fine." Rule of thumb: for ownership, add the blocked persons' interests together.