The Financial Services Authority ("FSA") has published the findings of a thematic review into anti-bribery and corruption (ABC) systems and controls in investment banks. In particular the FSA found a number of common weaknesses in firms in that: (i) most firms had not properly taken into account the FSA’s rules covering bribery and corruption, either before the implementation of the Bribery Act or after; (ii) nearly half the firms sampled did not have an adequate ABC risk assessment; (iii) management information on ABC was poor, making it difficult for the FSA to see how firms’ senior management could provide effective oversight; (iv) only two firms sampled had either started or carried out specific ABC internal audits; (v) there were significant issues in firms’ dealings with third parties used to win or retain business; (vi) though many firms had recently tightened up their gifts, hospitality and expenses policies, few had processes to ensure gifts and expenses in relation to particular clients/projects were reasonable on a cumulative basis. In light of the findings from the thematic review the FSA is consulting on proposed amendments to the regulatory guide entitled Financial crime: a guide for firms.