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Practitioner's note: a compliance check for a trader in Zug

The practitioner who reviews the anti-corruption and anti-money-laundering position of a trader in Zug should ask the following questions. Does the board receive regular reports on compliance risks and on the functioning of the programme? Has the company conducted a risk assessment that covers its countries, counterparties, products and intermediaries? Is there a documented due diligence procedure for intermediaries that has been applied to every current intermediary? Are payments to intermediaries controlled and justified by documented services? Are the traders trained in the risks of their markets? Is there a whistleblowing channel, and are reports investigated? Does the company screen its counterparties and transactions for sanctions and verify the origin of the goods where due diligence obligations apply? Does the company retain the documentation of its compliance programme for a sufficient period? The answers to these questions determine whether the company could defend itself against a charge under Article 102 if one of its employees or intermediaries were found to have paid a bribe.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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