ICG AC (CGCAT) study guide
ICG AC (CGCAT) · Work through your exam, one topic at a time.
The ICG Anti-Corruption (CGCAT) credential is a professional certification aimed at people who design, run, audit or advise on anti-bribery and anti-corruption (ABC) controls. Typical candidates work in compliance, internal audit, risk, legal, finance, procurement or investigation roles, and increasingly in third-party management or ESG-adjacent functions where corruption risk intersects with supply chains. The ICG AC (CGCAT) study guide has 9 sections and about 2,417 words.
01Bribery and Corruption Concepts and Terminology
This domain checks whether you can classify a payment correctly and use statutory vocabulary precisely. Examiners reward candidates who distinguish bribery from extortion, active from passive conduct, and direct from indirect payments.
330 words, about 2 min02International Legal and Regulatory Framework
The US Foreign Corrupt Practices Act 1977 has anti-bribery and accounting provisions. Anti-bribery covers issuers, domestic concerns and certain foreign persons acting in US territory.
332 words, about 2 min03Risk Assessment and Due Diligence of Third Parties
Third-party risk is assessed before appointment and throughout the relationship. Score country risk, sector risk, government touchpoints, payment structure, use of intermediaries and the counterparty’s ownership.
267 words, about 1 min04Anti-Corruption Programme Design and Governance
An anti-corruption programme should be proportionate to risk but must cover top-level commitment, risk assessment, policies and procedures, governance, training and communication, third-party management, financial controls, whistleblowing, monitoring and remediation. ISO 37001 and the UK Bribery Act guidance’s six principles are useful benchmarks.
262 words, about 1 min05Facilitation Payments
A facilitation payment is a small payment to a low-level official to secure or expedite a routine, non-discretionary action the payer is already entitled to, such as processing a visa or clearing goods. It is not a payment to obtain business or to change a decision.
262 words, about 1 min06Gifts, Hospitality and Conflicts of Interest
Gifts and hospitality are permitted only when bona fide, proportionate, transparent and not intended to influence a decision. Cash and cash equivalents are almost never acceptable.
277 words, about 1 min07Financial Controls, Books and Records, and Red Flags
The FCPA accounting provisions require issuers to keep books and records that accurately and fairly reflect transactions and to maintain a system of internal accounting controls. False invoices, off-book accounts, side letters and vague descriptions can breach these provisions even if no bribe is proven.
268 words, about 1 min08Investigations, Whistleblowing and Remediation
Provide confidential and anonymous channels, a non-retaliation policy and clear triage. Log concerns, assess bribery risk, escalate serious allegations to the board or audit committee, and protect reporters.
202 words, about 1 min09Enforcement, Sanctions and Cooperation with Authorities
The US DOJ and SEC enforce the FCPA; the UK SFO and other agencies enforce the Bribery Act. Outcomes include guilty pleas, deferred prosecution agreements, non-prosecution agreements, declinations and monitorships.
217 words, about 1 min