“If our people fail to act with integrity, the consequences for the firm are potentially very severe. It can affect our reputation. It can affect our relationship with our clients. It can affect our relationship with our regulators. And in some cases, it can have very profound consequences either for lawsuits or other enforcement actions brought against the firm. Understanding the risks associated with bribery and corruption and ensuring that issues get escalated are important responsibilities we all share.”
– Kathryn Ruemmler, Chief Legal Officer and General Counsel
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Welcome
Integrity and honesty are at the heart of everything we do.
We hold ourselves accountable to the highest ethical standards and we must each take personal responsibility for complying with anti-bribery and anti-corruption laws and policies.
For example, when is it risky to do business with a third party, such as an intermediary, vendor or business partner? Identifying and escalating the red flags of bribery and corruption will help to protect the firm’s and your personal reputation.
Know the red flags, stop and escalate.
While the firm has a robust control framework, one of our best defenses against bribery and corruption remains the vigilance of our people and our collective commitment to doing the right thing.
Whether you’ve been at the firm for one year or thirty years – everyone needs to take this training annually. Take the time to go through this module and be thoughtful in your responses.
Did You Know…
approximately 90% of all bribery enforcement actions have involved intermediaries/finders?
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Defining Intermediaries
Intermediaries are third parties who are engaged directly or indirectly by the firm or another party to provide services in connection with potential business opportunities (Review to advance). The third party does not need to be compensated by the firm or other parties and the business opportunities do not need to materialize for the third party to be considered an intermediary.
Direct and Indirect Intermediaries
Let’s break down the differences between Direct and Indirect intermediaries.
There are certain third-party activities that take place in the ordinary course of the firm’s business and may be excluded. For details, see the Firmwide Policy on Intermediaries/Finders.
Select each image button to learn more.
Direct Intermediaries
Third parties engaged and/or compensated by the firm to:
- Find, introduce, identify, source or maintain business opportunities;
- Interact with or introduce the firm to public officials or government entities (Review to advance) related to a business opportunity;
- Satisfy a condition or requirement of a client, prospective client, public official or government entity in the firm’s involvement of a business opportunity.
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Indirect Intermediaries
Third parties engaged and/or compensated by a client, underwriting syndicate, co-investor, counterparty, acquisition target, or another non-firm party involved in a business opportunity with the firm to provide referral, introductory or advisory services.
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Time to Focus: Learn the Red Flags
Some of the common red flags are when the intermediary:
Does not have a defined role and will not provide any services in the transaction, but participates in, or facilitates, the firm’s business discussions with the client or public officials
Is introduced or recommended by a public official or government entity in connection with a transaction
Requests payments to or retention of a public official or a Politically Exposed Person (PEP) or their immediate family members or close associates
Refuses to include the firm’s standard anti-bribery provisions into the contract covering the intermediary arrangement
Is located and/or operating in a high-risk jurisdiction (Review to advance)
Will receive unusually high fees or other compensation/benefits
Provides an invoice that appears falsified or with inflated amounts, or duplicative or vague descriptions of services
Has no identifiable media profile
Appears unqualified for the services being provided
For a full list of red flags, including those related to transactions, review the Firmwide Policy on Intermediaries/Finders.
Put it into Practice (Case 1 — Direct Intermediary)
Read the following situation and answer the question that follows.
An Asset Management (AM) Private team is looking to purchase a food and beverage company, owned by the family of a senior public official in Vietnam. A third-party individual who is well-connected in the industry introduces the business opportunity to Han, an MD in AM. Han engages the individual to act as an advisor. The advisor, who has faced media allegations of accounting fraud related to his own companies, introduces Han to the brother of the public official who is overseeing the sale of the company. The public official must approve the sale and will benefit from the proceeds of the sale.
Which one of the following is NOT a red flag for bribery and corruption risk in this situation? Note: Read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
Red flags for this situation are that the business opportunity located in Vietnam (a high-risk jurisdiction) was introduced by a third party. GS then engaged him as an advisor, making the individual a Direct Intermediary. The advisor is also acting as a go-between with the brother of the public official, and therefore, he may be politically exposed. Furthermore, the advisor has been the subject of adverse media. The transaction also benefits and requires the approval of a public official, which creates a potential for a bribe.
Under the Firmwide Policy on Intermediaries/Finders, firm personnel must escalate the introduction of a business opportunity by an individual as a potential intermediary to AB&C for review and pre-approval before the proposed engagement.
Sorry, that’s not quite right.
Red flags for this situation are that the business opportunity located in Vietnam (a high-risk jurisdiction) was introduced by a third party. GS then engaged him as an advisor, making the individual a Direct Intermediary. The advisor is also acting as a go-between with the brother of the public official, and therefore, he may be politically exposed. Furthermore, the advisor has been the subject of adverse media. The transaction also benefits and requires the approval of a public official, which creates a potential for a bribe.
Under the Firmwide Policy on Intermediaries/Finders, firm personnel must escalate the introduction of a business opportunity by an individual as a potential intermediary to AB&C for review and pre-approval before the proposed engagement.
Sorry, that's not right.
Red flags for this situation are that the business opportunity located in Vietnam (a high-risk jurisdiction) was introduced by a third party. GS then engaged him as an advisor, making the individual a Direct Intermediary. The advisor is also acting as a go-between with the brother of the public official, and therefore, he may be politically exposed. Furthermore, the advisor has been the subject of adverse media. The transaction also benefits and requires the approval of a public official, which creates a potential for a bribe.
Under the Firmwide Policy on Intermediaries/Finders, firm personnel must escalate the introduction of a business opportunity by an individual as a potential intermediary to AB&C for review and pre-approval before the proposed engagement.
Put it into Practice (Case 2 — Indirect Intermediary Involved in SCT)
Let’s review another situation involving intermediaries.
Global Banking & Markets (GBM) Private was mandated on a complex financing to complete a public infrastructure project for a Bolivian state-owned enterprise (SOE). John is a PMD in GBM Private. One of John’s former colleagues, who is advising the head of the Bolivian SOE, recommended Goldman Sachs for the opportunity and introduced John to the head of the SOE. Given the complex nature of the transaction and the involvement of a government client in a high-risk country (List 3b), the transaction was designated as a Significant and Complex Transaction (SCT).
As part of the SCT due diligence process, the deal team was asked to complete due diligence questions (SCT DDQ), including questions about (i) the involvement of an intermediary or any other high-risk third party and (ii) the deal team’s or intermediary’s interactions with public officials. The deal team answered “no” to both questions.
Did the deal team answer the due diligence questions correctly?
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
While the former colleague of the GBM Private PMD is a former employee of GS, he may be an Indirect Intermediary as he is advising the SOE. Also, both the former colleague as well as the GBM Private PMD appear to be having interactions with the head of the SOE, who is a public official, and therefore this question should have been answered “yes” as well.
The SCT DDQ must be answered accurately in order for proper anti-bribery due diligence to be completed. Inadvertent omissions or inaccuracies may negatively impact and/or delay the transaction.
Sorry, that’s not quite right.
While the former colleague of the GBM Private PMD is a former employee of GS, he may be an Indirect Intermediary as he is advising the SOE. Also, both the former colleague as well as the GBM Private PMD appear to be having interactions with the head of the SOE, who is a public official, and therefore this question should have been answered “yes” as well.
The SCT DDQ must be answered accurately in order for proper anti-bribery due diligence to be completed. Inadvertent omissions or inaccuracies may negatively impact and/or delay the transaction.
Sorry, that's not right.
While the former colleague of the GBM Private PMD is a former employee of GS, he may be an Indirect Intermediary as he is advising the SOE. Also, both the former colleague as well as the GBM Private PMD appear to be having interactions with the head of the SOE, who is a public official, and therefore this question should have been answered “yes” as well.
The SCT DDQ must be answered accurately in order for proper anti-bribery due diligence to be completed. Inadvertent omissions or inaccuracies may negatively impact and/or delay the transaction.
Requirements
The Firmwide Procedures for Significant and Complex Transactions describe the SCT governance and diligence processes related to SCTs and call attention to red flags of bribery and corruption, including:
- A third party introducing a public official or government entity in connection with a transaction
- A third party who does not have a defined role and will not provide any services in the transaction but who (i) participates in or facilitates the firm’s business discussions with the client or public officials, (ii) will receive financial or other compensation, and/or (iii) operates in a jurisdiction outside the scope of the transaction
- Known or reported allegations, legal proceedings or investigations relating to bribery, corruption, fraud, money laundering, government sanctions or other financial crimes
All Intermediaries (Direct or Indirect) must be (i) disclosed in the SCT Memorandum and DDQ and (ii) escalated to Compliance for further review.
Did You Know…
The firm currently has over 9,800 vendor relationships?
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Time to Focus: Learn the Red Flags
Some of the common red flags are when the vendor or other third party:
Is managed, owned or controlled by public officials
Provides entertainment to public officials
Charges unusually high or unexplained fees
Has received negative media or whistleblowing allegations that suggest fraud, bribery or other financial crime risks
Is located in or operating in high-risk jurisdictions
Obtains licenses, permits or other government approvals on behalf of the firm
Is recommended to the firm by a public official or government entity
Put it into Practice
The firm is entering into a joint venture with an investment firm based in Texas to invest in artificial intelligence (AI)-powered logistics start-ups. The investment firm would like to hire as a vendor a well-connected former state official, who is working as a lobbyist, to meet with local authorities about AI regulations. The lobbyist will act on behalf of the joint venture entity. Media reports have attributed the lobbyist’s connections to state officials and successful record to well-timed political contributions to key state legislative decision-makers. While negotiating the contract with the joint venture, the lobbyist asks for an advance payment of US$400,000 without explaining the purpose of the payment.
Which one of the following is NOT a red flag for bribery and corruption risk in this situation? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
Red flags for this situation are that the vendor asked for advance payment, is a former public official and has been accused of making political contributions to promote her causes. Taken together, these facts make it highly possible that the lobbyist will make a corrupt payment on behalf of the joint venture.
Sorry, that’s not quite right.
Red flags for this situation are that the vendor asked for advance payment, is a former public official and has been accused of making political contributions to promote her causes. Taken together, these facts make it highly possible that the lobbyist will make a corrupt payment on behalf of the joint venture.
Sorry, that's not right.
Red flags for this situation are that the vendor asked for advance payment, is a former public official and has been accused of making political contributions to promote her causes. Taken together, these facts make it highly possible that the lobbyist will make a corrupt payment on behalf of the joint venture.
Did You Know…
the firm evaluated approximately 900 Relationship Candidates in 2024?
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Overview
The firm welcomes and considers all qualified candidates for employment (Review to advance) and internships, regardless of their connections. However, the firm has very specific rules on hiring relationship candidates (Review to advance).
Time to Focus: Learn the Red Flags
Some of the common red flags for relationship candidates are when:
An external party who refers a candidate recommends the relationship candidate on the same e-mail chain that discusses a pending business transaction
A GS employee who refers the relationship candidate (internal referrer) wants to hire the candidate despite relatively weak qualifications or negative interview feedback
Internal or external parties indicate the importance of a client or the potential benefits to the firm if the relationship candidate is hired/interviewed
An internal referrer contacts interviewers and alerts them to the relationship candidate’s connection to a client
A GS employee puts pressure on HCM for updates or excessively coaches the relationship candidate (e.g., editing resume, providing tips on specific interview questions, and/or offering multiple prep sessions or multiple introductions to firm personnel compared to non-relationship candidates)
The firm appears to create a position specifically for the relationship candidate
The internal referrer arranges interviews for a relationship candidate outside of the firm’s standard HCM recruiting process
Review the requirements set out under the Firmwide Policy on Relationship Candidates for more details.
Put it into Practice
Lisa, a PMD in AM Private, receives an email from a client (senior partner of a private equity firm) who is considering GS, among other firms, to partner with the private equity firm for a high-profile investment opportunity. After mentioning the competitive pool of potential partners, the client says that his son is applying for internships at GS and that he would appreciate if Lisa could “put in a good word.” Lisa offers to “do whatever I can to get him across the line.” Lisa coaches the client’s son by editing his resume, invites the son for a work shadow, and prepares him multiple times with specific interview questions. Lisa also reaches out to the son’s Superday interviewers, indicating the importance of the client relationship, and seeks frequent updates from HCM.
Which one of the following is NOT a red flag for bribery risk in this situation? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
Red flags for this situation are that the PMD, knowing that GS was competing for business from the client, promised the client that she would get the son “across the line.” The PMD’s excessive coaching and outreach to the interviewers and HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s obtaining business.
The Firmwide Policy on Relationship Candidates requires internal referrers to step away after flagging the client connection to HCM, prohibits excessive coaching, and prohibits attempting to influence the candidate’s interviewers. Even if there was no corrupt intent, poorly worded communications to a candidate’s interviewers can cause the firm to reject otherwise qualified candidates.
Sorry, that’s not quite right.
Red flags for this situation are that the PMD, knowing that GS was competing for business from the client, promised the client that she would get the son “across the line.” The PMD’s excessive coaching and outreach to the interviewers and HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s obtaining business.
The Firmwide Policy on Relationship Candidates requires internal referrers to step away after flagging the client connection to HCM, prohibits excessive coaching, and prohibits attempting to influence the candidate’s interviewers. Even if there was no corrupt intent, poorly worded communications to a candidate’s interviewers can cause the firm to reject otherwise qualified candidates.
Sorry, that's not right.
Red flags for this situation are that the PMD, knowing that GS was competing for business from the client, promised the client that she would get the son “across the line.” The PMD’s excessive coaching and outreach to the interviewers and HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s obtaining business.
The Firmwide Policy on Relationship Candidates requires internal referrers to step away after flagging the client connection to HCM, prohibits excessive coaching, and prohibits attempting to influence the candidate’s interviewers. Even if there was no corrupt intent, poorly worded communications to a candidate’s interviewers can cause the firm to reject otherwise qualified candidates.
At the Core
What do you need to know about gifts, travel and entertainment? Follow these “Do’s” and “Don’ts”.
Do
Submit pre-approval requests in Concur for:
- All gifts (prior to purchase) to clients or other third parties, including Restricted Recipients (Review to advance)
- All travel and entertainment of Restricted Recipients, regardless of the cost
- All travel and entertainment (including ticketed events) to all other clients or third parties that you know in advance or expect will exceed US$250 per person
Accurately report and record the total value of all gifts, travel and entertainment in Concur in a timely manner, even if part or all of the expense is paid with personal funds and you are not seeking reimbursement.
Only request reimbursement for valid business expenses. You are expected to carefully review your own expenses, even if the reports are prepared by others on your behalf.
Disclose and seek approval via the firm’s Receipt of G&E Tool before accepting gifts with a value exceeding US$100 or travel/entertainment with a value exceeding US$250 from third parties with whom or which the firm has a business relationship. (Regional or divisional rules may set lower thresholds for disclosure and approval).
Don't
Offer, promise or authorize gifts, travel and entertainment to improperly influence government or regulatory action, to obtain or maintain business or an improper business advantage.
Inappropriate expensing, inaccurate reporting or improper offering of gifts, travel or entertainment will result in disciplinary action.
Time to Focus: Learn the Red Flags
Some of the common red flags for gifts, travel and entertainment are:
Excessive entertainment of a single individual who is a key client decision-maker
Entertaining a Restricted Recipient without seeking pre-approval
Charging inappropriate personal expenses to client projects
Inviting a current or prospective client to a potentially lavish event ahead of a non-routine deal pitch
“Topping off” or failing to report the full value of gift, travel or entertainment provided by absorbing the excess amounts from personal funds
Adding attendees to request for approval to reduce the per-person cost
Review the core principles of the Firmwide Policy on Gifts, Travel, and Entertainment for more details.
Put it into Practice
Mark from GBM Public is leading a team that is competing with several other banks to win a mandate from a sovereign wealth fund (SWF) in Turkey. Mark knows that the head of the SWF is traveling to New York with his family on vacation for the weekend. Mark arranges luxury accommodations and exclusive tourist events for the entire family, at his own expense. Knowing that Compliance would not approve of the nature of the hospitality or the cost, Mark did not seek pre-approval. He reasoned that he was paying for the expenses himself, so there would be no harm from a regulatory or reputational standpoint.
Which one of the following is NOT a red flag for bribery risk in this situation? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
The red flags for this situation include Mark not seeking pre-approval prior to entertaining a Restricted Recipient and paying for the entertainment using personal funds to avoid scrutiny.
Entertaining a Restricted Recipient client in and of itself is not a red flag, but the high-cost coinciding with the timing of the entertainment during deal discussions is a red flag. Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Firm personnel must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee.
Sorry, that’s not quite right.
The red flags for this situation include Mark not seeking pre-approval prior to entertaining a Restricted Recipient and paying for the entertainment using personal funds to avoid scrutiny.
Entertaining a Restricted Recipient client in and of itself is not a red flag, but the high-cost coinciding with the timing of the entertainment during deal discussions is a red flag. Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Firm personnel must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee.
Sorry, that's not right.
The red flags for this situation include Mark not seeking pre-approval prior to entertaining a Restricted Recipient and paying for the entertainment using personal funds to avoid scrutiny.
Entertaining a Restricted Recipient client in and of itself is not a red flag, but the high-cost coinciding with the timing of the entertainment during deal discussions is a red flag. Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Firm personnel must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee.
Think about it…
Many of our people are passionate about their political and charitable affiliations. Unfortunately, under certain circumstances these activities can present elevated bribery and corruption risks or at least raise the appearance of impropriety.
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Overview
Keep in mind that rules with respect to political activities are complex and vary by jurisdiction with severe penalties for violations.
Similarly, charitable contributions, including to bona fide charities, must never be made if the intent or effect is to inappropriately influence the business judgement of any person, including a public official, client, potential client, or government action.
So, if you are unsure – ask questions and seek guidance from Compliance.
At the Core
What do you need to know about political and charitable contributions?
Select each image button to learn more.
Never Solicit Contributions for Improper Purposes
Never make or solicit a political or charitable contribution or engage in political or charitable activity to improperly influence or obtain or retain business or a business advantage or government action.
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Be Aware of Appearances
Even contributions to bona fide charities may create the appearance of potential bribery or corruption, if linked to firm business, or a government action.
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Seek Pre-approval
Certain business-related charitable contributions, such as those related to public officials or government entities, high-risk jurisdictions or pending non-routine business, must be pre-approved by Anti-Bribery & Corruption.
The firm also requires pre-approval before our people (and in certain cases or jurisdictions, spouses and dependents) make political contributions or otherwise engage in political activity.
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Time to Focus: Learn the Red Flags
Some of the common red flags for charitable contributions include:
A public official requesting or otherwise associated with a contribution
Donation solicitation received from, or recipient charity located in a jurisdiction known to be high-risk for bribery and corruption
Communications that suggest the award or contracting of business is dependent on making a contribution
The firm has pending business with the client requesting contribution
A lack of transparency around the bank account for the charitable recipient
Review the Firmwide Policy on Charitable Contributions for a full list of red flags.
Put it into Practice
Anna, a VP in Wealth Management, invites you to attend the annual gala for a non-profit charity, which she supports. Anna mentions that she has purchased a table for the gala at the request of a prospective client who founded the non-profit. Later that day, you are copied on an e-mail where the prospective client thanks Anna for purchasing the table and states that he will now open a private banking account considering the recent charitable contribution.
Which of the following is a red flag for bribery risk in this situation? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
A red flag for this situation is that the prospective client indicates that he is opening a private bank account with GS because the VP purchased a table at the gala.
The fact that the prospective client founded the non-profit or that the VP supports the organization are not red flags. It is common for high-net-worth individuals to have either founded or serve in board or other leadership positions at non-profits and for the firm to support worthy causes.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from AB&C in Compliance.
Sorry, that’s not quite right.
A red flag for this situation is that the prospective client indicates that he is opening a private bank account with GS because the VP purchased a table at the gala.
The fact that the prospective client founded the non-profit or that the VP supports the organization are not red flags. It is common for high-net-worth individuals to have either founded or serve in board or other leadership positions at non-profits and for the firm to support worthy causes.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from AB&C in Compliance.
Sorry, that's not right.
A red flag for this situation is that the prospective client indicates that he is opening a private bank account with GS because the VP purchased a table at the gala.
The fact that the prospective client founded the non-profit or that the VP supports the organization are not red flags. It is common for high-net-worth individuals to have either founded or serve in board or other leadership positions at non-profits and for the firm to support worthy causes.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from AB&C in Compliance.
Scroll down to continue.
Abdul receives a cold call from a financial consultant to discuss a potential opportunity to onboard ultra-high net worth individuals from the Middle East. The potential clients are known to be linked to a royal family.
The consultant has no public profile or track record but claims to have relationships with the potential clients. The consultant says that the potential clients need to be onboarded quickly and he expects a significant finder’s fee for the introduction.
Which one of the following is NOT a red flag in this situation? Note: Read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
Red flags are that the consultant has no public profile, the consultant’s qualifications are questionable, and the consultant expressed urgency in onboarding the clients who may be politically exposed. The correct course of action is to escalate to Compliance as a potential Direct Intermediary.
For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
Sorry, that’s not quite right.
Red flags are that the consultant has no public profile, the consultant’s qualifications are questionable, and the consultant expressed urgency in onboarding the clients who may be politically exposed. The correct course of action is to escalate to Compliance as a potential Direct Intermediary.
For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
Sorry, that's not right.
Red flags are that the consultant has no public profile, the consultant’s qualifications are questionable, and the consultant expressed urgency in onboarding the clients who may be politically exposed. The correct course of action is to escalate to Compliance as a potential Direct Intermediary.
For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
The firm agreed to hire MLT Group, a vendor located in Dallas, to serve as the operating partner for a real estate development project, which will require zoning approvals. The vendor will hire and oversee the general contractor, which will be responsible for zoning approvals and licenses.
GS and the vendor execute a contract with a detailed statement of work (SOW). The Vendor Relationship Owner (VRO) later learns that, outside the scope of the SOW, the vendor has engaged another third party who is the general contractor’s brother and who serves on the city’s zoning committee.
The vendor tells the VRO that the consultant is an “old friend” who will “grease the wheels” to avoid costly delays. The vendor also asks GS to make additional payments, over and above the consultant’s standard fee, to expedite zoning approvals.
Should you escalate this vendor to Compliance? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.
That’s correct.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. The firm could ultimately be held liable for a third party’s corrupt actions.
Improper intent could be inferred by such statements, including that the third party may, directly or indirectly, pay bribes or facilitation “grease” payments to those in a position of influence to get business advantages. Any such payment, even if the value appears immaterial, is prohibited. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Sorry, that’s not quite right.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. The firm could ultimately be held liable for a third party’s corrupt actions.
Improper intent could be inferred by such statements, including that the third party may, directly or indirectly, pay bribes or facilitation “grease” payments to those in a position of influence to get business advantages. Any such payment, even if the value appears immaterial, is prohibited. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Sorry, that's not right.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. The firm could ultimately be held liable for a third party’s corrupt actions.
Improper intent could be inferred by such statements, including that the third party may, directly or indirectly, pay bribes or facilitation “grease” payments to those in a position of influence to get business advantages. Any such payment, even if the value appears immaterial, is prohibited. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Marco, an Analyst in the Tax Division, decided to engage a Mexican law firm to provide tax advice regarding a proposed transaction in Mexico. Marco came across an article regarding an investigation by Mexican authorities into facilitation of tax evasion and kickbacks by certain law firms, including the Mexican firm.
Reasoning that the investigation was in the early stages, Marco proceeded to onboard the vendor without informing his manager or Compliance.
What should Marco do? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
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That’s correct.
Negative media about a vendor under investigation by authorities for facilitation of tax evasion, bribery or other financial crimes is a serious matter and should be escalated to your manager and AB&C.
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Negative media about a vendor under investigation by authorities for facilitation of tax evasion, bribery or other financial crimes is a serious matter and should be escalated to your manager and AB&C.
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Negative media about a vendor under investigation by authorities for facilitation of tax evasion, bribery or other financial crimes is a serious matter and should be escalated to your manager and AB&C.
Francesca, a VP in AM Private, is responsible for summer internship recruitment. Her manager refers a candidate after the application deadline, stating that the candidate is the son of a senior executive at an “important client.” AM Private is pitching co-investment opportunities to the executive, and her manager states that hiring the candidate would “put Goldman Sachs in a good position.”
The candidate does not appear to be sufficiently qualified for the role, but without notifying HCM, Francesca arranges for members of her team to interview the candidate. Francesca tells the interviewers that the candidate is connected to a client and was referred by an MD.
Which one of the following is NOT a red flag in this situation? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
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That’s correct.
The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” while knowing that there are pending business discussions. Also, Francesca should have informed HCM that her team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that her manager requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to AB&C for review and approval before the candidate receives a verbal or written offer, in order to ensure that the hiring is based on merit.
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The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” while knowing that there are pending business discussions. Also, Francesca should have informed HCM that her team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that her manager requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to AB&C for review and approval before the candidate receives a verbal or written offer, in order to ensure that the hiring is based on merit.
Sorry, that's not right.
The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” while knowing that there are pending business discussions. Also, Francesca should have informed HCM that her team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that her manager requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to AB&C for review and approval before the candidate receives a verbal or written offer, in order to ensure that the hiring is based on merit.
Ankit, an Associate in Engineering, is having lunch with a former colleague who is an elected official in Bengaluru. The next day, the official sends Ankit an e-mail with his nephew’s resume attached.
What should Ankit do? Remember to read the options carefully.
Select the option you think is correct and then select Submit.
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That’s correct.
The nephew is a Relationship Candidate, as he was referred by a public official. Ankit may refer the nephew to the firm as a candidate but must disclose the connection to a public official to HCM to ensure that AB&C reviews the candidate. Ankit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Ankit should tell the official that, due to internal policy, he cannot influence or be involved in the hiring process but will forward the nephew’s resume to the firm’s recruiting team, which will advise on next steps.
As explained in the Firmwide Policy on Relationship Candidates, decisions to offer, hire or retain Relationship Candidates may create the appearance that the firm is doing so improperly as an inducement or quid pro quo, or in consideration for prior or current business, to secure pending or future business, or to seek favored treatment from a government entity or regulator. Relationship Candidates must be interviewed, evaluated and hired through a merit-based process.
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The nephew is a Relationship Candidate, as he was referred by a public official. Ankit may refer the nephew to the firm as a candidate but must disclose the connection to a public official to HCM to ensure that AB&C reviews the candidate. Ankit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Ankit should tell the official that, due to internal policy, he cannot influence or be involved in the hiring process but will forward the nephew’s resume to the firm’s recruiting team, which will advise on next steps.
As explained in the Firmwide Policy on Relationship Candidates, decisions to offer, hire or retain Relationship Candidates may create the appearance that the firm is doing so improperly as an inducement or quid pro quo, or in consideration for prior or current business, to secure pending or future business, or to seek favored treatment from a government entity or regulator. Relationship Candidates must be interviewed, evaluated and hired through a merit-based process.
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The nephew is a Relationship Candidate, as he was referred by a public official. Ankit may refer the nephew to the firm as a candidate but must disclose the connection to a public official to HCM to ensure that AB&C reviews the candidate. Ankit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Ankit should tell the official that, due to internal policy, he cannot influence or be involved in the hiring process but will forward the nephew’s resume to the firm’s recruiting team, which will advise on next steps.
As explained in the Firmwide Policy on Relationship Candidates, decisions to offer, hire or retain Relationship Candidates may create the appearance that the firm is doing so improperly as an inducement or quid pro quo, or in consideration for prior or current business, to secure pending or future business, or to seek favored treatment from a government entity or regulator. Relationship Candidates must be interviewed, evaluated and hired through a merit-based process.
Xinmin is a VP in GBM Public in Singapore, and her friend is now a board member of a OneGS client that is majority-owned by the government. She would like to invite her friend and his wife to a Formula 1 event to discuss business.
What should Xinmin do?
Select the option you think is correct and then select Submit.
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Although the client may be a friend, this event should be raised for pre-approval, as the purpose of this entertainment is to discuss business, the client is a Restricted Recipient, and it is a high-cost event.
The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel and entertainment of Restricted Recipients (which include employees of government entities), even the most nominal, must be pre-approved. The client may need to self-pay depending on the entity’s rules. Also, there may be additional diligence and transparency letter requirements for high-value entertainment.
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Although the client may be a friend, this event should be raised for pre-approval, as the purpose of this entertainment is to discuss business, the client is a Restricted Recipient, and it is a high-cost event.
The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel and entertainment of Restricted Recipients (which include employees of government entities), even the most nominal, must be pre-approved. The client may need to self-pay depending on the entity’s rules. Also, there may be additional diligence and transparency letter requirements for high-value entertainment.
Sorry, that's not right.
Although the client may be a friend, this event should be raised for pre-approval, as the purpose of this entertainment is to discuss business, the client is a Restricted Recipient, and it is a high-cost event.
The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel and entertainment of Restricted Recipients (which include employees of government entities), even the most nominal, must be pre-approved. The client may need to self-pay depending on the entity’s rules. Also, there may be additional diligence and transparency letter requirements for high-value entertainment.
Jorge is an MD in Brazil. He is handling a request from the CEO of a prospective client to contribute US$2,500 to a non-profit organization.
The prospective client’s CEO is currently running for political office and sits on the board of directors of the non-profit organization. A similar request was approved last year.
What should Jorge do?
Select the option you think is correct and then select Submit.
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That’s correct.
This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
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This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
Sorry, that's not right.
This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
Jessica’s team from GBM Private is advising a client on raising capital to acquire certain assets of a digital currency company. The client is eager to tap into this market and told Jessica that they will be engaging a financial advisor that is well-connected to potential investors in Saudi Arabia.
Jessica is not familiar with the advisor, it appears to be new and unlicensed, and its scope of services appears to be outside of ordinary activities, including interacting with the local ministry.
What should Jessica do?
Select the option you think is correct and then select Submit.
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Even though it may be common for a client to engage financial advisors in these types of transactions, if the financial advisor is headquartered or operating in a high-risk jurisdiction or appears unlicensed/unregulated/unqualified or providing services which may include interacting with public officials, then it should be escalated to Compliance for review and approval.
Indirect Intermediaries are third parties engaged and/or compensated by a client, underwriting syndicate, co-investor, counterparty, acquisition target, or another non-firm party to provide referral, introductory or advisory services (including with respect to government introductions and approvals) with respect to a business opportunity. They may present potential legal or reputational risks to the firm.
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Even though it may be common for a client to engage financial advisors in these types of transactions, if the financial advisor is headquartered or operating in a high-risk jurisdiction or appears unlicensed/unregulated/unqualified or providing services which may include interacting with public officials, then it should be escalated to Compliance for review and approval.
Indirect Intermediaries are third parties engaged and/or compensated by a client, underwriting syndicate, co-investor, counterparty, acquisition target, or another non-firm party to provide referral, introductory or advisory services (including with respect to government introductions and approvals) with respect to a business opportunity. They may present potential legal or reputational risks to the firm.
Sorry, that's not right.
Even though it may be common for a client to engage financial advisors in these types of transactions, if the financial advisor is headquartered or operating in a high-risk jurisdiction or appears unlicensed/unregulated/unqualified or providing services which may include interacting with public officials, then it should be escalated to Compliance for review and approval.
Indirect Intermediaries are third parties engaged and/or compensated by a client, underwriting syndicate, co-investor, counterparty, acquisition target, or another non-firm party to provide referral, introductory or advisory services (including with respect to government introductions and approvals) with respect to a business opportunity. They may present potential legal or reputational risks to the firm.
Attestation
Thank you for completing Goldman Sachs Compliance Learning: Anti-Bribery and Anti-Corruption 2025 Financial Crime Compliance.
If you do not understand any part of this training, please refer to the relevant policies, and if you are still unsure, you must exit the training now and contact the Anti-Bribery & Corruption Group or your Compliance officer.
Before you leave, please attest to the following statement by selecting Submit.
