CORAA

Anti-Bribery & Anti-Corruption (ABAC) Compliance Audit Checklist

Gift/hospitality registers, facilitation-payment red flags, and third-party due diligence — the controls that keep a bribe from being booked as a legitimate business expense.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Governing law
Prevention of Corruption Act, 1988 (as amended 2018)
Key registers
Gift & hospitality register, third-party due diligence file
Common gap
Facilitation payments booked under vague expense heads
Format
Microsoft Word (.docx)
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ANTI-BRIBERY & ANTI-CORRUPTION (ABAC) COMPLIANCE AUDIT CHECKLIST

Entity: ___ · Period: ___

Scope: controls preventing bribery and corruption in dealings with government officials and private-sector counterparties — gift/hospitality registers, facilitation-payment red flags, and third-party (agent/distributor/consultant) due diligence. Relevant alongside the Prevention of Corruption Act, 1988 (as amended 2018) for dealings with public officials, and increasingly required by multinational customers/investors with their own ABAC policies.

Risk & Control Matrix

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This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

What counts as a "facilitation payment" and why is it a red flag?
A facilitation payment is a small, informal payment made to a government official to expedite a routine action they are already obligated to perform (e.g. releasing an already-approved permit faster). Even where small in value, these are typically prohibited under a properly drafted ABAC policy and can constitute an offence — the red flag in an audit is finding such payments disguised under vague expense categories like "miscellaneous" or "facilitation charges."
Why does third-party due diligence matter if the bribe is paid by the agent, not the entity?
Under the Prevention of Corruption Act (2018 amendment) and most corporate ABAC frameworks, an entity can be held liable for bribery committed by an intermediary acting on its behalf, even without direct knowledge, if it failed to have "adequate procedures" in place. Due diligence before engaging agents/distributors is the entity's primary defence against this exposure.
Is a gift and hospitality register only needed for gifts given to government officials?
No — a well-designed register covers both directions (given and received) and both public officials and private-sector counterparties, since private-sector corruption (e.g. a purchasing manager favouring a vendor for personal gifts) carries its own commercial and reputational risk even where it is not a Prevention of Corruption Act offence specifically.
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