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WHITE PAPER

Compliance & Ethics

The blind spot report: How compliance teams uncover unknown ABAC risk

The bribery risks that reach a regulator are usually well understood by the profession and still invisible inside your own program. This report shows you the four conditions that let ABAC risk hide, and a review cycle to surface it early. 

Last updated: July 30, 2026

Authors:

EQS Content Team

  • Why three out of four foreign bribery cases run through a third party, and what that means for your controls (OECD Foreign Bribery Report) 
  • The four conditions that let ABAC risk go undetected: fragmented data, the spreadsheet trap, unchecked familiarity, and a limited audit trail 
  • The blind spot review cycle: a quarterly routine to identify, measure, manage and adapt 
  • What recent enforcement shows about the cost of a missed connection, including the SFO’s 2026 Ultra Electronics DPA 
  • A set of questions to pressure-test the visibility of your own program 

For Chief Compliance Officers, Heads of Compliance and ABAC program owners who need to show a program that works in practice and can prove it. 

A compliance blind spot is a risk an organization cannot see, even when the risk itself is well understood. It emerges when information about bribery, third parties or conflicts of interest is fragmented across separate systems, so no single view reveals the pattern until an incident or a regulator exposes it. 

The most damaging blind spots are the ones a program has not found yet. This report gives you a repeatable way to find them. 

  • European regulatory-first heritage: built around EU directive timelines, with an understanding of how regulators investigate, not only what they require. 
  • A single environment: whistleblowing, third parties, cases and policies in one platform, so there are no audit-trail gaps between separate tools. 
  • Investigative defensibility: every action timestamped and every decision logged, ready for the moment a regulator asks for evidence. 
  • Compliance-specialist support: implementation and ongoing help from people who work in compliance. 

See how connected compliance data works day to day. Explore the EQS Compliance Cockpit 

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