ICG AC (CGCAT) study plan

Define bribery, extortion, kickbacks, trading in influence and money laundering, and distinguish each from legitimate gifts and facilitation payments

Map the elements of a bribery offence (intent, undue advantage, public official, business advantage) and apply them to three short fact patterns

Build a one-page comparison of FCPA anti-bribery and accounting provisions, UK Bribery Act section 1, 2, 6 and 7 offences, OECD Convention and UNCAC scope and reach

Explain jurisdictional bases: territorial, nationality, corporate liability and the UK section 7 failure-to-prevent offence with its adequate-procedures defence

Analyse the FCPA's third-party payment and knowledge standard ('knowing' wilful blindness) and how it drives intermediary risk

Identify red flags in third-party onboarding files and rank them by severity with a written rationale

Draft risk-based due diligence questions covering ownership, beneficial ownership, government touchpoints and payment routing

Explain the role of the OECD Good Practice Guidance on internal controls and the 2021 anti-bribery recommendation in shaping due diligence

Design a tiered due diligence model (low, medium, high risk) with defined triggers for enhanced diligence and continuous monitoring

Draft contract clauses covering anti-corruption representations, audit rights, termination and training obligations

Compare the six principles of the UK Bribery Act guidance with the FCPA Resource Guide hallmarks of an effective compliance programme

Assign accountability for the compliance programme across board, senior management, compliance function and business units

Write a risk assessment methodology that scores bribery risk by country, sector, transaction type and counterparty

Explain how books-and-records requirements under the FCPA and UK Bribery Act apply to off-book accounts, slush funds and improper journal entries

Identify financial red flags: unusual commissions, cash payments, round-sum invoices, payments to offshore accounts and duplicate vendors

Design three preventive controls (segregation of duties, payment approval thresholds, vendor master-file review) and state the test for each

Distinguish facilitation payments from bribes and state the legal position under the FCPA, UK Bribery Act and OECD Convention

Set gift and hospitality thresholds, approval workflows and recording requirements, and apply them to five borderline scenarios

Identify, disclose and manage conflicts of interest, including those arising from relatives in government or third-party ownership

Link expense-claim and hospitality records to books-and-records accuracy and red-flag detection

Draft an investigation protocol covering intake, scoping, evidence preservation, interviews, legal privilege and reporting lines

Explain whistleblowing channel design, anonymity, non-retaliation and the EU Whistleblower Directive principles

Plan a remediation programme: root-cause analysis, control redesign, disciplinary action and monitoring

Apply the conflict-of-interest and gifts rules to an investigation scenario where a manager approved a related-party vendor

Explain the incentives for self-disclosure and cooperation under the FCPA Corporate Enforcement Policy, DOJ guidance and UK Deferred Prosecution Agreements

Describe the sanctions landscape: fines, disgorgement, debarment, monitorships and individual liability

Outline how authorities coordinate across borders and what mutual legal assistance means for evidence gathering

Prepare a self-report decision memo weighing voluntary disclosure, waiver of privilege and cooperation credit

Consolidate all eight domains into a single one-page summary sheet of definitions, frameworks and thresholds

Complete two timed 60-question practice sets and review every wrong answer to its source rule

Re-test weak areas by rewriting any missed concept in your own words with a scenario example

Rehearse explaining the adequate-procedures defence and the FCPA accounting provisions aloud in under two minutes each