Brussels - Anti-Bribery & Anti-Corruption Compliance: running your business with integrity
7 rue Joseph Stevens
1000 Brussels
Belgium
- Bribery
- AML
- Public‑sector bribery
- Private‑sector bribery
- Private-sector corruption
- Public-sector corruption
- Undue advantage
- Low‑value gift
- Misappropriation
- Trading in influence
- Unlawful exercise of public functions
- Abuse of functions
- Obstruction of justice
- Enrichment from corruption offences
- Concealment
- Crypto assets
- Illegal political financing
- Penalties and measures for natural persons
- Liability of legal persons
- Measures for legal persons
- Aggravating circumstances
- Mitigating circumstances
- Privilege or immunity
- Limitation period
- Anti-corruption bodies
- Anti corruption frameworks
- ABAC policies
- Internal controls
- Approval workflows
- Gifts & hospitality
- Conflicts of interest management
- Code of conduct alignment
- Continuous improvement of compliance programs
- Compliance program assessments & remediation
- Monitoring national transposition of the Directive
- Ethics and compliance program design
- Tone at the top anti corruption
- Corruption prevention framework
- Corporate integrity program
- Corruption risk assessments
- Gap analyses
- Third party due diligence
- Supplier & intermediary screening
- High risk jurisdiction assessment
- Beneficial ownership checks
- Integrity due diligence
- Third party due diligence failures (investigations)
- Vendors assessment
- Secure corruption reporting channels
- Confidential reporting mechanisms
- Multilingual reporting channels
- Case triage & assessment
- Handling bribery, corruption & fraud reports
- Non retaliation protections
- Whistleblower confidentiality & anonymity obligations
- Anti corruption investigations
- Bribery investigations
- Misappropriation investigations
- Trading in influence investigations
- Obstruction of justice investigations
- AML investigations
- Sanctions & export controls investigations
- Fraud, embezzlement & financial misconduct investigations
- Dawn raids & regulatory inspections
- Cross border enforcement actions
- Evidence handling
- Cooperation with authorities
- Criminal & administrative liability (individuals & entities)
- Anti corruption training
- Manager & employee training
- Third party training
- Tabletop exercises
- Ethical decision making training
- Investigations preparedness
- Regular training on expanded offence catalogue (Directive)
- Crisis response
- Reputation management
- High risk case management
- Strategic response to corruption allegations
- Pre acquisition ABAC due diligence
- Post acquisition remediation
- Compliance integration
- Transactional risk assessment
- Cross border compliance & enforcement cooperation
The Significance of Anti‑Bribery & Anti‑Corruption Compliance
Anti-bribery and anti-corruption (“ABAC”) compliance has become a core expectation for organisations operating in the EU and globally. Companies are increasingly expected to demonstrate that they can prevent, detect and respond to corruption risks through clear policies, effective controls and a culture of integrity. A strong ABAC framework is no longer just good governance — it is essential to protecting your organisation’s reputation, resilience and long-term value.
A well-designed compliance programme enables you to identify risks early, address concerns before they escalate, and show regulators, investors and stakeholders that your organisation takes integrity seriously. It strengthens trust, supports ethical decision-making, and reduces the financial and reputational impact of corruption-related incidents.
The new EU Anti-Corruption Directive will further raise expectations by requiring organisations to implement more structured measures or update their existing ABAC compliance programmes, including internal controls, risk assessments and reporting mechanisms. While national implementation will vary, the direction of travel is clear: proactive, comprehensive compliance is becoming the standard.
Liberius is monitoring the transposition of the Directive across all 27 EU Member States and will provide regular updates, including an implementation tracker to help organisations stay informed and prepared.
At Liberius, we help organisations build and operate ABAC programmes that are practical, defensible and aligned with business realities, using a risk-based approach. Our ABAC team combines legal expertise with operational insight to guide you through complex regulatory requirements while safeguarding your commercial interests.
Our ABAC Expertise
ABAC programs Governance & Compliance
- Designing and implementing anti‑corruption programs that are practical, defensible and aligned with regulatory expectations, or updating the existing one to new European requirements.
- Developing governance structures, internal controls, policies and procedures tailored to your organization’s risk profile.
- Conducting ABAC risk assessments and maturity reviews to identify gaps and prioritize improvements.
- Ensuring alignment with the EU Anti‑Corruption Directive and national transposition requirements across all 27 Member States.
- Advising on documentation standards, record‑keeping and compliance reporting obligations.
- Supporting third-party vendor selection process and implementation.
- Monitoring Member State implementation of the EU Anti‑Corruption Directive to ensure ongoing compliance.
Anti-Corruption Hotlines & Report Handling
- Designing and implementing multilingual anti-corruption reporting channels aligned with legal and regulatory standards.
- Designing triage processes for bribery, corruption and fraud reports, ensuring timely and discreet handling.
- Monitoring Member State implementation of the EU Anti-Corruption Directive to ensure ongoing compliance.
- Assessing and triaging bribery, corruption, and fraud reports with urgency and discretion.
- Protecting confidentiality, anonymity, and non-retaliation obligations.
Internal & Anti-Corruption Investigations
- Developing ABAC investigation protocols, governance frameworks, and documentation standards.
- Ensuring investigation processes comply with local, EU, and cross-border legal requirements (e.g., data privacy, legal privilege).
- Conducting fair, thorough and defensible investigations into allegations of bribery, corruption and financial misconduct.
- Managing cross‑border ABAC investigations involving multiple jurisdictions, regulators and legal systems.
- Handling interviews, evidence collection, digital forensics and document review with precision and discretion.
- Coordinating with HR, Legal, Compliance, IT and external experts to ensure a controlled and compliant process.
- Supporting organizations during regulatory inquiries, dawn-raids, and enforcement actions.
- Advising on crisis communication, reputational risk, and stakeholder management.
- Designing escalation pathways, decision-making structures, and case closure criteria.
Training, Culture & Preparedness
- Training teams on ABAC red flags, reporting obligations and investigation best practices.
- Preparing teams for interviews, evidence handling, and high‑risk decision‑making.
- Building a speak-up culture and ABAC awareness through targeted communication strategies.
- Running tabletop exercises and scenario-based simulations for high-risk situations (e.g., bribery, third-party misconduct).
- Supporting companies in embedding ethical behaviour and integrity into daily operation, and ethical decision-making.
Litigation, Enforcement & Regulatory Response
- Responding to regulatory investigations, enforcement actions, and criminal proceedings related to corruption.
- Managing interactions with supervisory authorities, law enforcement, and prosecutors.
- Advising on remediation, corrective actions, and post-investigation improvements (e.g., enhancing controls, disciplining wrongdoers).
- Supporting companies in settlement discussions, deferred prosecution agreements (DPAs), or follow-up on litigation.
- Coordinating cross-border regulatory strategy, multi-jurisdictional defense, and stakeholder management.
Our approach
- Senior only advice → You work directly with senior attorneys experienced in anti-corruption matters and internal investigation frameworks.
- Business aligned thinking → We design ABAC compliance program and investigation processes that support — rather than disrupt — day-to-day operations and strategic objectives.
- Speed and clarity → When a report comes in, timing matters. We provide clear, practical guidance from the outset, without jargon or unnecessary complexity.
- Structured, defensible processes → Our methods ensure investigations are fair, consistent, and compliant with the applicable legal requirements.
- Tech-enabled reporting and case management → We help you integrate secure reporting channels and investigation tools, working with trusted technology providers to ensure confidentiality and efficiency.
Who We Advise
- Multinationals navigating complex, cross border compliance.
- Domestic companies operating in a single jurisdiction.
- SMEs, start ups, and family owned businesses.
- Companies across all industries and sectors.
Contact our team
- Alja Poler De Zwart / Partner – Whistleblowing, Investigations & Compliance, ABAC
Alja advises organisations on the assessment and investigation of internal concerns, anti-bribery and anti-corruption risks, communication with complainants and implicated individuals, and interactions with regulators. She works closely with HR, Compliance, Legal, Privacy and IT teams to ensure investigations and ABAC processes are fair, defensible and aligned with legal and operational requirements. - Jean-Marc Meilleur / Partner – Crisis Management, Investigations & Strategic Advisory, ABAC
Jean-Marc brings decades of experience as a former Prosecutor of the King in Brussels, magistrate, corporate legal counsel and strategic crisis advisor. With a 360° legal perspective, he advises organisations on sensitive and high-stakes investigations, including matters involving senior leadership, potential criminal exposure and reputational risk. Drawing on his expertise in strategy, communication and change management, he helps organisations respond with clarity, control and stability when it matters most. - Elisabeth Puistienne / Partner - Corporate & Commercial, M&A and Restructuring, ABAC
Elisabeth brings more than two decades of experience in senior international in-house leadership roles at global and US companies. She brings practical ABAC (Anti-Bribery and Anti-Corruption) compliance expertise, grounded in a risk-based approach and a deep understanding of business needs and challenges. Skilled at navigating cross-border regulatory complexities to deliver actionable, commercially driven solutions. She partners with organizations to facilitate their business growth.
FAQs – What Clients Ask Us
What does an effective ABAC compliance program look like in practice?
A modern program combines clear policies, practical controls, meaningful training, and a structured approach to identifying and managing risks, all underpinned by an internal culture that is sensitive to the risks at stake. It should be proportionate to your organization’s size and exposure — and capable of demonstrating that you take integrity seriously.
How should we conduct an ABAC risk assessment?
An ABAC risk assessment should be tailored to your business model, markets and third‑party relationships. It does not need to be overly complex, but it must be systematic, documented and updated regularly to remain credible.
What level of due-diligence is expected for third parties and intermediaries?
Regulators increasingly expect risk‑based due diligence that goes beyond basic checks. The depth of review depends on the country’s and company’s environment and culture, nature of the relationship, and potential business exposure. A structured, proportionate approach is essential.
How do we handle internal reports or allegations of bribery or corruption?
Allegations should be assessed promptly, confidentially and in line with a clear protocol. Even initial triage matters: early steps can significantly influence the quality of the investigation and the organization’s regulatory position.
What documentation will regulators expect us to maintain?
Expectations vary by jurisdiction, but regulators generally look for evidence of policies, controls, training, risk assessments, due diligence and investigation processes. Documentation does not need to be burdensome — it simply needs to be consistent and reliable.
How can we prepare for regulatory inquiries or cross‑border enforcement actions?
Preparation starts long before an inquiry arrives. Clear governance, defensible processes and well‑maintained records make it easier to respond efficiently and reduce exposure. Early strategic advice can make a significant difference.
Will Liberius provide updates on how the Directive is implemented across the EU?
Yes. We will monitor transposition across all 27 Member States and provide regular updates, including an implementation tracker, so organizations can stay informed and prepare in a timely, coordinated way.
Newsroom
Stay informed through our latest ABAC insights, external publications and updates on the evolving anti-bribery and anti-corruption landscape across Europe.
Our ABAC team will regularly share updates, insights and external publications on the implementation of the EU Anti-Corruption Directive and broader anti-bribery and anti-corruption developments across Europe.
Liberius — Anti‑Bribery & Anti‑Corruption, protecting your organisation from corruption risks before they become legal, financial, or reputational crises.
Tracked and Reviewed by Experts
This tracker is a joint initiative between Mitratech and Liberius. Mitratech maintains the platform and ongoing monitoring. Liberius provides legal review of all country-level content and specialist expertise across EU anti-bribery and anti-corruption law. Together, the aim is to give compliance teams a reliable and practical resource they can trust as national laws evolve across all 27 Member States.