European Union - Anti-Bribery and Corruption

Module Scope

1. Does the organisation prevent, detect, and respond to bribery and corruption across its operations, governance arrangements, and business relationships?
2. Do the organisation's governance structures provide effective oversight and accountability for anti-bribery and corruption compliance at the senior management and board level?
3. Does the organisation manage its exposure to cross-border liability and cooperate effectively with competent authorities during investigations and enforcement actions?
4. Does the organisation maintain transparency over its ownership, financial dealings, and assets to prevent the concealment of corruption proceeds?

Module Application

The EU ANTI-BRIBERY AND CORRUPTION module guides organisations on meeting their legal responsibilities to prevent, detect, and respond to bribery and corruption across their activities within the European Union. It addresses the obligations that apply to an organisation's officers, employees, agents, and intermediaries in their dealings with public officials, private-sector counterparties, and third-party partners, and covers the governance, conduct, reporting, and transparency measures required under European Union law.

The EU ANTI-BRIBERY AND CORRUPTION module provides information to organisations about how to comply with legal responsibilities when dealing with the following:

• Prohibition of active and passive corruption in both the public and private sector
• Prevention of the offering, giving, requesting, or accepting of undue advantages, including through intermediaries
• Integrity and fair competition in procurement, including mandatory exclusion of economic operators convicted of corruption
• Governance arrangements, board accountability, and supervision to prevent corporate liability
• Risk assessment and due diligence on business partners, agents, and intermediaries
• Confidential whistleblower reporting channels and protection against retaliation
• Multi-jurisdictional criminal liability and response to cross-border enforcement orders
• Cooperation with competent authorities, Financial Intelligence Units, asset recovery offices, and EU-level bodies
• Record-keeping, compliance monitoring, and independent assurance on sustainability disclosures
• Beneficial ownership identification, registration in central registers, and access controls
• Prevention of money laundering and traceability of proceeds derived from corruption

The EU ANTI-BRIBERY AND CORRUPTION module also comprehensively covers requirements arising under key European Union instruments, including:

• The Convention on the fight against corruption involving officials of the European Communities and of Member States
• The Council Framework Decision on combating corruption in the private sector
• The Council Decision 2008/852/JHA 
• OECD Anti-Bribery Convention
• UN Convention Against Corruption (UNCAC)
• Criminal Law Convention on Corruption (Council of Europe)
• The Directive on the fight against fraud to the Union's financial interests by means of criminal law
• The Anti-Money Laundering Directive and the Directive on combating money laundering by criminal law
• The Directive on public procurement
• The Directive on the freezing and confiscation of instrumentalities and proceeds of crime and the Directive on asset recovery and confiscation
• The Regulation on the mutual recognition of freezing orders and confiscation orders and the Framework Decision on mutual recognition of financial penalties
• The Directive on the protection of persons who report breaches of Union law
• The Directive on annual financial statements, consolidated financial statements, and related reports
• The Directive facilitating the use of financial and other information for the prevention and investigation of criminal offences
• The Regulation on a general regime of conditionality for the protection of the Union budget
• The Regulation on the protection of the European Communities' financial interests

Organisations, their directors, and their employees are expected to be familiar with the broad landscape of anti-bribery and corruption obligations that apply under European Union law, together with the specific obligations relevant to their sector, size, corporate structure, and cross-border footprint.

The EU ANTI-BRIBERY AND CORRUPTION module should be subscribed to by any organisation that:

• Operates within the European Union or has activities, personnel, or assets connected to a Member State
• Engages with public officials, Union officials, or national officials in the course of its business
• Conducts business relationships with private-sector counterparties, agents, or intermediaries where corruption risks may arise
• Is a legal person that may incur criminal or administrative liability in one or more Member States
• Is an obliged entity under European Union anti-money laundering requirements
• Participates in public procurement procedures in the European Union
• Is subject to European Union sustainability reporting and assurance requirements covering anti-bribery and anti-corruption governance
• Holds bank accounts, beneficial ownership structures, or other assets within Member States that may be subject to financial transparency and traceability requirements

The specific questions and answers covered by the module include:

• How to prohibit and prevent active and passive corruption across public and private sector dealings
• How to uphold integrity and fair competition in procurement and exclude economic operators with relevant corruption convictions
• How to establish governance arrangements, board oversight, and senior management accountability for anti-bribery and anti-corruption compliance
• How to assess corruption risks and conduct enquiries into business partners, agents, and intermediaries
• How to operate confidential reporting channels and protect persons who report breaches against retaliation
• How to map jurisdictional exposure across Member States and manage multi-jurisdictional liability
• How to respond to cross-border freezing orders, confiscation orders, and financial penalty decisions
• How to cooperate with competent authorities, Financial Intelligence Units, and asset recovery offices during investigations
• How to maintain complete and retrievable records for required retention periods
• How to obtain independent assurance on sustainability disclosures addressing anti-bribery and anti-corruption matters
• How to identify beneficial owners and maintain accurate information in the applicable central register
• How to apply access controls and audit trails to prevent the concealment of corruption proceeds and support the traceability of assets

The EU ANTI-BRIBERY AND CORRUPTION module outlines an organisation’s obligations across the compliance lifecycle, including prevention, detection, investigation, enforcement, and asset recovery. It reflects the EU’s integrated framework, combining prohibitions on corrupt conduct with governance, cross-border cooperation, and financial transparency measures. The module supports organisations in understanding their responsibilities and in establishing a proportionate and effective compliance framework.

Non-compliance may result in significant criminal and administrative consequences, including penalties for individuals, fines for organisations, exclusion from public funding and procurement, and asset freezing or confiscation. Breaches may also lead to reputational damage, increased scrutiny, and loss of business opportunities.

LexisNexis Regulatory Compliance is a legal obligations register and alerting solution that combines regulatory content with technology to empower you to take control of your compliance obligations.