ISO 37001:2025 Transition — Lesson 2: Bribery Risk Assessment, Due Diligence, Functions, Partners, and Financial Controls

Learning Objectives

• Interpret the requirements, principles, roles, and dependencies shaping bribery risk assessment, due diligence, functions, partners, and financial controls.
• Apply a practical workflow and create a reviewable updated bribery risk and due-diligence workbook.
• Evaluate the exception where partner due diligence omits beneficial ownership changes and determine proportionate follow-up.

Detailed Topics

• Bribery Risk Assessment applied to the course scenario and expected evidence.
• Due Diligence applied to the course scenario and expected evidence.
• Functions applied to the course scenario and expected evidence.
• Partners applied to the course scenario and expected evidence.
• and Financial Controls applied to the course scenario and expected evidence.

Instructor Demonstration

The instructor traces a case involving a multinational organization updating anti-bribery governance, due diligence, controls, investigations, and partner oversight. The demonstration links decisions to objective evidence, records the result in updated bribery risk and due-diligence workbook, and tests the condition where partner due diligence omits beneficial ownership changes.

Hands-On Exercise

Complete a controlled exercise covering Bribery Risk Assessment, Due Diligence, Functions, Partners, and Financial Controls. Confirm scope and responsibilities, examine the stated exception, reach a supported conclusion, and preserve the outcome in updated bribery risk and due-diligence workbook.

1. Define the objective, boundaries, stakeholders, criteria, and expected work product.
2. Perform the activity while recording assumptions, observations, evidence, and decisions.
3. Test normal operation, the exception, and an escalation or follow-up condition.
4. Document conclusions, owners, deadlines, verification methods, and review triggers.

Scenario Analysis

• Identify the requirement or control with the strongest influence on the scenario outcome.
• Compare two defensible responses and explain their risk, operational, and evidence trade-offs.
• Decide how the updated bribery risk and due-diligence workbook should be approved, retained, reviewed, and updated.

Troubleshooting Guidance

Start where expected practice and observed evidence first diverge. Separate a missing record from an ineffective process, distinguish unclear ownership from a control failure, and treat “partner due diligence omits beneficial ownership changes” as a hypothesis until tested against the applicable criteria and intended outcome.

Validation Checklist

• Scope, roles, criteria, stakeholders, dependencies, and intended outcomes are explicit.
• The updated bribery risk and due-diligence workbook connects conclusions to objective, reviewable support.
• Normal operation, the stated exception, escalation, and follow-up were evaluated.
• Owners, due dates, verification methods, review triggers, and improvement actions are clear.

Lesson Outcome

Learners can apply Bribery Risk Assessment, Due Diligence, Functions, Partners, and Financial Controls, explain the reasoning used, and defend the result through updated bribery risk and due-diligence workbook.