32
© 2015 KPMG Services Pte Ltd Registration No: 200003956G, a Singapore incorporated company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ‘KPMG International’, a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm
has any authority to obligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Q. Do you have a formal process to
identify high risk Third Party Intermediaries Associated Persons
from an ABC perspective?
10 20
30 40
36 40
13 11
21 31
34
14
ASPAC Rest of the World
Q. Do all of your Third Party
Intermediaries Associated Persons contracts have a Right-to-audit clause
and have you exercised this right?
Yes 54
No 33
Don’t Know 13
Yes 45
No 40
Don’t Know 15
ASPAC
Enforcing compliance
34
Pushed by the OECD, member governments and partners have adopted tighter ABC regulations. In Asian and South American emerging markets,
enforcement agencies are becoming much more active.
79 of non-US and non-UK respondents listed elsewhere say they have developed formal ABC programs of their own. This may be due
to the threat of enforcement under the FCPA and Bribery Act on US and UK customers, expansion into US and UK markets, andor
growing regional enforcement.
87 of non-US or non-UK unlisted respondents doing business with US and UK entities, have formal ABC programs.
Survey shows a sharp increase in respondents who say they are highly challenged by ABC
© 2015 KPMG Services Pte Ltd Registration No: 200003956G, a Singapore incorporated company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ‘KPMG International’, a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm
has any authority to obligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
35
© 2015 KPMG Services Pte Ltd Registration No: 200003956G, a Singapore incorporated company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ‘KPMG International’, a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm
has any authority to obligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Q. Does your company have a formal,
