Glossary

A Points – Agenda items adopted by the Council of the European Union without discussion, as they have been pre-agreed at lower levels.

ABC – anti-bribery and corruption – A catch-all term for policies and procedures to tackle bribes and corrupt practices. It usually includes gifts and hospitality, dealing with public officials, and when to make reports. It will outline an organisation’s stance against bribery and corruption.

ACAMS – Association of Certified Anti-Money Laundering Specialists – The largest global membership organisation dedicated to fighting financial crime. It provides training and certification, runs conferences and disseminates information on detection and prevention of money laundering

ADI – authorised depository institution – An Australian term for A financial institution licensed by the Australian Prudential Regulatory Authority (APRA) to carry on banking business, including accepting deposits from the public. Essentially an Australian bank.

AFC – anti-financial crime – A catch-all term for policies and procedures for tackling financial crime. Financial crime could include tax evasion, fraud and bribery as well as money laundering.

AFSI (Adjusted Financial Statement Income) – A measure used to determine a corporation’s taxable income under the Corporate Alternative Minimum Tax (CAMT) in the United States.

AIM – alternative investment market – Commonly known as AIM, this is a sub-market of the LSE (London Stock Exchange). AIM caters to smaller, more risky companies. Those listed tend to be more speculative, partly because of AIMs more relaxed regulations and listing requirements as opposed to FTSE firms.

AML (Anti-Money Laundering) – Regulations designed to prevent criminals from disguising illicit gains as legitimate income. Many bribery cases involve money laundering to conceal corrupt payments.

AML/CFT – anti-money laundering/countering the financing of terrorism (also used for combating the financing of terrorism) – A more accurate acronym for anti-money laundering. A key element of AML is the prevention of funds being laundered by terrorists, as well as criminals. Countering the financing of terrorism involves the same policies and procedures as standard AML, but includes an awareness of the way money laundering benefits terrorist organisations and acts of mass violence.

AMLC – Anti-Money Laundering Council – The Filipino agency responsible for implementing the anti-money laundering law of The Philippines.

AMLD – Anti Money Laundering Directive – A directive of the European Union on countering money laundering. Directives, unlike regulations which are directly applicable in member states, are not directly applicable and must be ‘transposed’ by each member state into national law. There are currently six directives on money laundering. EU member states must update their national laws when new directives are released.

AMLSF – Anti-Money Laundering Supervisors Forum – A British AML organisation created by HM Treasury in 2007 to bring together all the bodies in the UK designated as supervisory authorities (such as the FCA and ICAEW) under the UK money laundering regulations. It aims to share and develop consistent best practice across AML.

Antici – A system named after an Italian diplomat, the Antici Group prepares high-level discussions in the European Council ensuring smooth decision-making at the heads of state and heads of government level.

APA (Accredited Parliamentary Assistant) – A staff member supporting an MEP in research, administration, and legislative work.

ATAD (Anti-Tax Avoidance Directive) – An EU directive aimed at preventing tax avoidance practices that affect the functioning of the internal market.

B Points – Agenda items on the Council’s agenda that require discussion and are not pre-approved.

BACS (Bankers’ Automated Clearing System) – An electronic system in the UK for processing financial transactions, including direct debits and credits.

BCRs (Binding Corporate Rules) – Internal rules adopted by multinational companies to allow the transfer of personal data within their group across borders, ensuring compliance with data protection standards.

BO – beneficial owner(ship) – A natural person (human being) who owns or controls a legal person (business or organisation), and on whose behalf a transaction is conducted. A person is generally a beneficial owner if they own or control a certain percentage of the organisation, usually 25%.

BSA (Bank Secrecy Act) – A US law requiring financial institutions to maintain records and report suspicious transactions, including those linked to tax evasion.

BVI (British Virgin Islands) – A well-known offshore jurisdiction often associated with secrecy in financial transactions. Shell companies registered in BVI have been linked to corruption and bribery schemes.

BYOD (Bring Your Own Device) – A policy allowing employees to use their personal devices for work purposes, which necessitates measures to protect organizational data accessed or stored on these devices.

CAMT (Corporate Alternative Minimum Tax) – A US tax policy that imposes a 15% minimum tax on large corporations earning over $1 billion annually to address corporate tax avoidance.

CARF (Crypto-Asset Reporting Framework) – An OECD framework designed to enhance transparency by mandating the exchange of tax-relevant information on cryptocurrency transactions between tax authorities.

CATS (Article 36 Committee) – A committee that coordinates police and judicial cooperation in criminal matters within the EU.

CCO (Corporate Criminal Offence) – A liability concept under the UK’s Criminal Finances Act 2017, making companies accountable for failing to prevent the facilitation of tax evasion.

CCPA (California Consumer Privacy Act) – A state statute intended to enhance privacy rights and consumer protection for residents of California, USA.

CE (Conformité Européenne) – A certification mark that indicates a product meets EU safety, health, and environmental protection standards. In the context of bribery, fake CE certificates can be used to fraudulently approve substandard goods.

CFT (Countering the Financing of Terrorism) – Regulations designed to detect and prevent the flow of funds to terrorist organisations, which often overlap with anti-money laundering efforts.

CIO (Chief Information Officer) – An executive responsible for managing and implementing information and computer technologies within an organization.

CISO (Chief Information Security Officer) – An executive responsible for overseeing and ensuring the security of information and data within an organization.

COPPA (Children’s Online Privacy Protection Act) – A U.S. federal law designed to protect the privacy of children under 13 by regulating online data collection practices.

Council Configurations – The Council of the EU meets in different configurations, depending on the policy area, such as the Environment Council or Transport Council.

Council Working Parties – The technical backbone of the Council, these groups consist of national experts who refine legislative proposals before they reach ambassadors or ministers.

CPRA (California Privacy Rights Act) – An amendment to the CCPA that enhances privacy rights and consumer protection for California residents.

CRS (Common Reporting Standard) – An OECD initiative requiring financial institutions to report foreign account holders’ financial details to their home tax authorities to combat tax evasion.

CSDP (Common Security and Defence Policy) – The EU’s policy framework for defence and crisis management, enabling joint military and civilian operations.

DAC (Directive on Administrative Cooperation) – An EU law that mandates cross-border tax information exchange among member states to improve tax transparency.

DAC6 (Directive on Administrative Cooperation 6) – An extension of DAC that obligates businesses and intermediaries to report cross-border tax arrangements that could be used for tax evasion or aggressive avoidance.

Delegated Act – A legal act allowing the European Commission to amend or supplement non-essential elements of legislation, subject to potential objections by the European Parliament or Council.

DNFBPs (Designated Non-Financial Businesses and Professions) – Sectors that, while not financial institutions, are susceptible to money laundering and terrorist financing, such as real estate agents, lawyers, and accountants.

DOJ (Department of Justice) – The US federal agency responsible for enforcing the FCPA and prosecuting companies and individuals involved in bribery and corruption.

Data Protection Act – Legislation enacted in various jurisdictions, such as the UK’s Data Protection Act 2018, that outlines the framework for data protection and privacy.

DPA (Deferred Prosecution Agreement) – A legal agreement between a corporation and a prosecuting authority, allowing the company to avoid a criminal conviction by meeting certain conditions, such as paying fines and improving compliance measures. DPAs are commonly used in cases of corporate tax evasion and financial crime.

DPIA (Data Protection Impact Assessment) – A process to help organizations identify and minimize data protection risks in projects that involve processing personal data.

DPM (Data Protection Manager) – An individual appointed within an organization to oversee data protection compliance. While not mandatory under the UK GDPR, appointing a DPM is considered good practice for managing data protection responsibilities.

DPO (Data Protection Officer) – A designated individual within an organization responsible for overseeing data protection strategy and compliance with GDPR or other data protection laws.

DSA (Data Sharing Agreement) – A formal agreement between organizations outlining the terms and conditions for sharing personal data, ensuring compliance with data protection laws.

DSPT (Data Security and Protection Toolkit) – A self-assessment tool used by UK organizations, particularly within the National Health Service (NHS), to measure their performance against data security and protection standards.

ECOFIN (Economic and Financial Affairs Council) – A configuration of the Council of the European Union where economics and finance ministers from all member states discuss economic policy, fiscal matters, and regulation of financial services.

EITI (Extractive Industries Transparency Initiative) – A global standard promoting transparency and accountability in the oil, gas, and mining sectors to prevent bribery and illicit financial flows.

EPC (Economic Policy Committee) – A committee that provides economic analyses and opinions to the Council and the European Commission, particularly concerning economic growth and structural reforms.

European Conservatives and Reformists (ECR) Group – A centre-right to right-wing group that includes conservative and Eurosceptic parties. The ECR advocates for reforming the EU, respecting national sovereignty, and promoting free enterprise.

European People’s Party (EPP) – A centre-right political group representing Christian democratic parties across EU member states. The EPP advocates for policies promoting European integration, economic growth, and social market economy principles.

Facilitation Payment – A small bribe given to expedite routine government actions, such as visa approvals. Unlike other bribes, facilitation payments may be tolerated in some jurisdictions but are illegal under the UK Bribery Act.

FAC (Foreign Affairs Council) – A formation of the Council of the European Union where foreign ministers discuss the EU’s external action, including foreign policy, defence, trade, and development cooperation.

FCPA (Foreign Corrupt Practices Act) – A US law prohibiting companies and individuals from bribing foreign officials to gain a business advantage. It is one of the most enforced anti-corruption laws worldwide, often applied to multinational firms.

FPO (Foreign Public Official) – A government official from another country. Bribing an FPO is a specific offence under the UK Bribery Act and the US FCPA.

FSA (Financial Services Authority, UK) – The former UK financial regulatory body responsible for enforcing anti-bribery measures in the financial sector before its functions were transferred to the FCA and PRA.

G20 ACWG (G20 Anti-Corruption Working Group) – A coalition within the G20 that develops policies to combat corruption and enhance international cooperation in enforcing anti-bribery laws.

GAAP (Generally Accepted Accounting Principles) – A set of accounting standards and procedures used in the United States to ensure consistency in financial reporting, aiding in the detection and prevention of tax evasion.

GAAR (General Anti-Abuse Rule) – A UK and EU regulation that enables tax authorities to counteract transactions deliberately designed to evade taxes.

GAERC (General Affairs and External Relations Council) – A former configuration of the Council that was split into the General Affairs Council (GAC) and the Foreign Affairs Council (FAC) to better focus on their respective areas.

GRECO (Group of States against Corruption) – A Council of Europe body that monitors member states’ compliance with anti-corruption standards and evaluates their policies.

Greens/European Free Alliance (Greens/EFA) – A political group combining green parties and regionalist parties. The Greens/EFA prioritises environmental issues and increased sustainability regulations.

Group Coordinator – The MEP responsible for coordinating their political group’s position within a parliamentary committee, influencing internal debates and voting strategies.

HMRC – His Majesty’s Revenue and Customs – The UK government department responsible for collecting taxes and paying some forms of state support, along with administering the minimum wage. It is the supervisory authority for money service businesses. Also a law enforcement agency tasked with investigating serious organised financial crime.

HMT – His Majesty’s Treasury – A UK government department which is the British finance and economics ministry, also known as the Exchequer and headed by the chancellor. Responsible for public finance and the UK government’s economic and financial services policy.

HNWI – high net-worth individual – An individual with a net worth of at least $1 million dollars in liquid assets, such as cash or investable assets. A very high net worth individual is someone with at least $5 million in liquid assets.

HRC – high-risk third country – A high-risk third country is one assessed as having strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. These countries will have been assessed by the FATF, and are usually published in a list by the EU, UK and US. A transaction from a high-risk third country will generally require enhanced due diligence.

ICO (Information Commissioner’s Office, UK) – The UK regulator for data protection and privacy, which may investigate bribery cases involving unauthorised access to personal or corporate data.

ID&V – identification and verification – This check identifies and verifies customers before they discuss an account or perform an automated transaction. It might take place through a phone application or web chat, and will ask the individual for a range of personal data such as account numbers and date of birth.

IFRS (International Financial Reporting Standards) – A set of global accounting standards. Compliance with IFRS helps prevent fraudulent financial reporting and concealment of bribery payments.

IMF (International Monetary Fund) – An international financial institution that provides guidance on anti-corruption measures as part of its economic policies and lending conditions.

Impact Assessment – A mandatory evaluation that the European Commission conducts before proposing new legislation, analysing potential economic, social, and environmental effects.

Implementing Act – A regulation specifying how EU laws should be applied in practice, adopted by the European Commission but under close scrutiny from member states.

INI (Own-Initiative Report) – A non-legislative report drafted by the European Parliament on topics where it wants to influence EU policy, often leading to legislative proposals later.

Inter-service Consultation – A process within the European Commission where different departments (DGs) review and provide input on draft proposals to ensure policy coherence.

IPO (Initial Public Offering) – The process by which a private company offers shares to the public for the first time. In anti-bribery contexts, IPOs can attract scrutiny if corruption risks, such as undisclosed payments, exist in a company’s financial history.

IR – independent review (an audit into the design and operational effectiveness of an AML programme) – An independent review is an audit that monitors the adequacy of a firms’ anti money laundering programme. It should be carried out by someone who understand the organisation, understands the money laundering risks, and is not involved in any part of the business to ensure it is independent.

IRC (Internal Revenue Code) – The primary body of tax laws in the United States, including provisions that define and penalise tax evasion.

JMLIT (Joint Money Laundering Intelligence Taskforce) – A UK initiative that fosters collaboration between law enforcement, banks, and regulators to combat money laundering and financial crime, including tax evasion.

MLCO – money laundering compliance officer – A role in an organisation who ensures internal compliance programmes and controls are adequate to counter money laundering risks. The MLCO must have a position on the board.

MLRO – money laundering reporting officer – This is the person who is nominated to consider suspicious activity reports. They are responsible for taking external SARs to the National Crime Agency. This person may also be the money laundering nominated officer (MLNO).

NCA – National Crime Agency (UK) – The UK law enforcement agency responsible for leading the UK’s fight against serious and organised crime. They also receive and review suspicious activity reports (SARs).

NFT (Non-Fungible Token) – A blockchain-based digital asset that can be used to obscure ownership and facilitate tax evasion through hidden asset transfers.

OECD (Organisation for Economic Co-operation and Development) – An international organisation that promotes policies to improve economic and social well-being. The OECD monitors global anti-bribery efforts and has criticised outdated bribery laws in some jurisdictions.

OFAC – Office of Foreign Assets Control – A US agency under the Department of the Treasury which administers and enforces economic and trade sanctions against US sanctions targets and Specially Designated Individuals (SDIs).

OFSI – Office of Financial Sanctions Implementation – A UK agency part of HM Treasury which implements and enforces economic sanctions against UK sanctions targets, levies fines for non-compliance, and produces guidance to ensure sanctions are properly understood.

OPBAS – Office for Professional Body Anti-Money Laundering Supervision – The UK body that supervises the 25 professional body supervisors in the legal and accountancy sectors. It aims to improve the consistency of professional body AML supervision, although it does not directly supervise legal or accountancy firms.

PAC (Political Action Committee) – An organisation that raises and spends money to influence political elections. PACs can be used to funnel bribes disguised as political contributions.

PbD (Privacy by Design) – An approach where privacy and data protection are embedded throughout the entire lifecycle of technologies and systems, from inception to deployment and disposal.

PCA (Permanent Court of Arbitration) – An international tribunal that resolves disputes between states and investors, including cases involving bribery and corruption in business contracts.

PCP – policies, control, procedure – These are the things regulated firm must establish and maintain to mitigate and manage effectively the risks of money laundering and terrorist financing identified by in their risk assessment. PCPs must cover a number of requirements as specified by the Money Laundering Regulations 2017.

PEP (Politically Exposed Person) – An individual with prominent public functions, such as politicians or senior government officials. Due to their position, PEPs are considered at higher risk for bribery and corruption.

PIPEDA (Personal Information Protection and Electronic Documents Act) – Canada’s federal privacy law for private-sector organizations, governing the collection, use, and disclosure of personal information.

PIPL (Personal Information Protection Law) – China’s comprehensive data protection law that regulates the processing of personal information within its jurisdiction.

POCA (Proceeds of Crime Act 2002) – An individual with significant ownership or control over a UK company, subject to transparency requirements to prevent hidden ownership structures facilitating tax evasion.

POPIA (Protection of Personal Information Act) – South Africa’s data protection law that aims to promote the protection of personal information processed by public and private bodies.

PPE (Personal Protective Equipment) – Equipment such as masks and gloves used in health and industrial settings. In bribery cases, fraudulent PPE procurement and false certification are risks, especially in crisis situations.

ROPA (Record of Processing Activities) – A mandatory record that organizations must maintain under GDPR, detailing all personal data processing activities to demonstrate compliance.

SAR (Suspicious Activity Report) – A report submitted by financial institutions to authorities when they suspect money laundering or tax evasion-related activities.

SCCs (Standard Contractual Clauses) – Legal tools provided by the European Commission to ensure appropriate data protection safeguards for personal data transferred outside the EU.

SFO (Serious Fraud Office, UK) – The UK government agency responsible for investigating and prosecuting serious or complex fraud, bribery, and corruption. The SFO has led several high-profile bribery investigations under the UK Bribery Act.

TI (Transparency International) – A global NGO dedicated to fighting corruption. TI publishes the Corruption Perceptions Index, ranking countries based on perceived levels of public sector corruption.

TRS (Trust Registration Service) – A UK system requiring trusts to disclose beneficial ownership information to prevent the use of trusts for tax evasion.

UBO (Ultimate Beneficial Owner) – The real person who ultimately owns or controls a company or trust, often concealed in tax evasion schemes.

UBS (Union Bank of Switzerland) – A Swiss financial institution involved in tax evasion scandals, serving as a case study for enforcement actions against banks facilitating tax fraud.

UK GDPR (United Kingdom General Data Protection Regulation) – The UK’s data protection framework that mirrors the EU GDPR, tailored to fit the UK’s legal system post-Brexit.

UKBA (UK Bribery Act 2010) – The United Kingdom’s comprehensive anti-bribery legislation, widely regarded as one of the world’s strictest anti-corruption laws. It criminalises offering, receiving, and failing to prevent bribery.

UNODC (United Nations Office on Drugs and Crime) – A UN agency focused on combating financial crimes, including tax evasion.

VAT (Value Added Tax) – A consumption tax applied in many countries, commonly targeted in tax evasion schemes such as fraudulent refund claims or underreporting sales.

WBG (World Bank Group) – An international financial institution that funds development projects. It enforces anti-bribery policies and blacklists companies involved in corrupt practices.