Tackling Bribery, Money-Laundering, Misconduct, Conflicts of Interest, and Sanctions Breaches in Healthcare

Healthcare providers play a crucial role in society – providing care for those in need. Most healthcare providers are either funded by the taxpayer or by payouts from insurance premiums, and they work with a variety of suppliers & service providers to run their complex operations. Due to their vast purchasing power – and dealings with large government contracts & supply chains – these types of organisations are often subject to bribery & corruption, money laundering, conflicts of interest, and they have an obligation to avoid dealings with sanctioned countries & providers – making compliance a top priority.

In this blog we take a journey through some of the core challenges faced by compliance teams in the healthcare sector. We explain how the latest GRC technology can support teams to implement anti-money laundering measures, avoid conflicts of interest, manage sanctions checks, prevent bribery & corruption, and implement an effective disclosures procedure.

What are the key compliance concerns in healthcare organisations and why?

Healthcare providers receive substantial funding from taxpayers or insurance premiums, making them accountable for the responsible use of public resources. The nature of their operations and the way they are funded and managed means they are dealing with high value government contracts.  Securing a large healthcare contract can be very lucrative for potential vendors who often use underhanded methods to secure these contracts resulting in bribery & corruption, money laundering, and sanctions breaches. Therefore, managing gifts & hospitality, disclosures, conflicts of interest, and performing sanctions checks are critical components for maintaining integrity and transparency within the healthcare sector.

Let’s examine each area in detail and explain how the latest GRC technology can automate these complex processes.

  1. Gifts & Hospitality

One of the major contributors to bribery & corruption involves the giving & receiving of corporate gifts & hospitality. Therefore, compliance teams must ensure that any gifts, experiences, and entertainment received or offered by employees aligns with protocols. They must ensure the correct approvals take place and keep a complete log of everything for audit purposes.

Traditionally organisations start out using spreadsheets to log this kind of activity – and any required approvals are done on an ad hoc basis through email. While this can be effective in smaller organisations, when you get into larger scale organisations with hundreds or even thousands of employees – with different reporting lines and approval chains and guidelines based on roles and locations – the activity becomes too complex for manual processes.

How can technology help? 

GRC technology makes it easy for organisations to implement a best-practice gifts & hospitality procedure to easily detect potential corrupt activity and bribes. Staff simply complete an online form to declare the benefit they have received or the gift they have given. The forms have standard fields to capture all the relevant details including who sent or received the gift, how much it was worth, when it was received and who by – many systems even allow you to upload relevant photos and associated URL’s. 

Once a gift or hospitality event is logged in the system and formally disclosed by the recipient, automation kicks in. Compliance teams can set a gift limit for each employee based on their country, office location, department, or role level. Workflows then automate the approval process & flag potential bribery. Rules can also be set to flag suspicious activity at a department or site level to pinpoint potential problems enabling areas of the business – that could be susceptible to bribery & corruption – to receive additional training. Leaders can view dashboards and drill down into different sites, departments, and individuals that are violating any policies and compliance teams can set and amend thresholds when policies are revised.

  1. Conflicts of Interest

Conflicts of interest within healthcare can erode public trust and compromise patient care. Vigilant management ensures that healthcare professionals make decisions based on medical necessity and patient well-being – rather than for personal or financial interest.

Healthcare providers must establish a clear conflicts of interest policy and educate & train staff on the importance of disclosures and implement a formal process for individuals to disclose any potential conflicts of interest. This may include financial interests, relationships with pharmaceutical companies & suppliers – and any other affiliations that could influence decision-making.

All potential conflicts of interest should be reviewed to assess their impact. When conflicts are identified, healthcare providers must develop & implement appropriate mitigation actions like revoking decision making authority, adjusting roles & responsibilities, or even dismissal.

Organisations must maintain thorough documentation of actions taken to manage conflicts of interest – this documentation is essential for demonstrating compliance with policies & regulatory requirements and provides a historical record for future reference.

How can technology help?

GRC technology can provide a structured way for organisations to capture & report on conflicts of interest. Each staff member can create a profile, providing relevant personal & professional information, including financial interests, relationships, and affiliations – this data is held on record. Users are required to provide comprehensive information about all factors that could influence decision-making along with any relevant attestations to company policies.

Staff can log potential conflicts of interest via online forms which can be customised to meet the needs of the organisation. Automated workflows escalate the matter to the relevant staff. A step-by-step process then kicks into action until the conflict is resolved with all actions captured in the platform for complete transparency. The organisation can run a variety of reports on policy adherence, types of conflicts, risk trends, and the effectiveness of mitigation strategies. This approach helps organisations to uphold ethical standards, ensure transparency, comply with regulations, and maintain the trust of stakeholders.

  1. Sanctions Checks

Healthcare providers rely on a vast network of suppliers to provide vital equipment, medical supplies, and staff to run hospitals, surgeries, and care facilities. Due to the way they are funded, they have a responsibility to ensure the contracts they make with suppliers are cost effective, reliable, and ethically sourced. This means that they must avoid dealing with sanctioned companies & countries.

Sanctions screening involves checking against an ever-changing list of businesses, organisations, individuals, and government agencies to protect against fraud and illicit activity.  These checks help to reduce identity theft, detect & prevent financial crime, and restrict trade with countries and entities that have broken international laws. Government sanction lists can be tricky to keep up with, and failure to comply can result in hefty fines. 

How can technology help?

GRC software enables organisations to keep an active register of sanctioned companies, countries, and jurisdictions. This ensures sanctions lists are correctly maintained & documented – and changes can be made in real time.

When a new supplier or employee is onboarded, teams input critical details around name, trading alias, registration number, country, trading partners, supply chain data, and origin of goods. Once this data is collected, the system will automatically check the data against the live sanctions list and flag potential problems. Automated workflows escalate potential sanctions breaches to the relevant stakeholder so they can make a formal decision regarding whether the deal or contract can proceed.

Economic sanctions can vary, with one governing body lifting sanctions while another continues to impose them. Those in the healthcare sector are required to maintain specific sanction screening controls and regulations and proactively perform risk assessments to ensure that sanctions are not being violated and that all dealings with sanctioned organisations are prohibited. Any violations of sanctions can result in hefty fines. Using technology to automate the process – and ensure everything is documented – provides assurance that deals with sanctioned organisations & companies are avoided.

  1. Disclosures & Whistleblowing

The healthcare sector has a duty to protect patients and staff, therefore it is critical that employees and patients feel that they can speak up and report areas of concern or mis treatment. Whether it is medical malpractice, unethical supplier relationships, sexual harassment & bullying, or unfair & bias treatment – staff should have a safe and discreet way to disclose this sensitive information to ensure the matter can be escalated & addressed appropriately.

Having a formalised & discreet way to report problems is crucial in order to maintain quality of care, uphold professional standards, prevent fraud & mismanagement, ensure regulatory compliance, and preserve organisational integrity. Establishing effective channels for reporting concerns – and ensuring protection for whistleblowers – contributes to a healthcare system that prioritises transparency, accountability, and continuous improvement.

How can technology help?

GRC software can provide a discreet portal with online forms making it easy for staff & patients to disclose problems or whistle blow. Staff simply complete an online form to report a potential area of misconduct or wrongdoing. Based on the data entered, automated workflows escalate the incident to the relevant stakeholder. All evidence is documented within the system and workflows enable teams to monitor each case until it is closed.

The software ensures the anonymity of those reporting and external portals can even be set up to enable patients and their families to report misconduct. As the information is captured, management teams can easily report on the data and start to understand the source of wider problems, enabling them to change staff, implement policies or take disciplinary action when needed. The evidence from the solution can be used in employee tribunals.

  1. Anti-Money Laundering

The healthcare sector can be vulnerable to money laundering due to the way it is funded and the large complex financial transactions that are required to source staff and medical supplies & equipment. The intricate nature of these sizeable transactions can provide opportunities for money launderers to disguise illicit funds within legitimate financial flows.

Stories often hit the headlines about corrupt government officials contracting with their own affiliates to secure large deals for healthcare providers. It is important that deals & contracts are scrutinised for fake invoices and fraudulent billing. Adequate anti-money laundering practices must be put in place to prevent fraudulent activity and meet compliance requirements.

How can technology help?

GRC software can support healthcare providers to detect, prevent, and mitigate the risks associated with money laundering activities. Most modern GRC platforms offer API integrations with other systems & data sources enabling organisations to set up controls & checks against financial transactions & customer data to detect any fraudulent activity.

The software can also be used to perform customer due diligence checks by easily rolling out questionnaires & surveys via online forms – with all data captured by the forms feeding directly into the platform so it can easily be checked and reported on. Software can also be used for transaction monitoring and scoring, and it can notify stakeholders of unusual, large, or duplicate transactions or unmatched invoices. The automated workflows in the platform streamline the AML process and facilitate comprehensive case management to ensure problems are escalated & resolved – capturing a complete audit trail of events.


Compliance teams within healthcare providers must be proactive in their approach to important areas like addressing bribery & corruption, conflicts of interest, money laundering, and sanctions breaches. There simply isn’t enough time for organisations to manage these critical areas manually with so many stakeholders involved and so many regulations, jurisdictions, and laws to comply with.

GRC software offers a whole host of capabilities to simplify & automate these procedures – eliminating manual checks & disjointed processes. The built in dashboards enable teams to understand their pending and overdue actions to address problem areas quickly. The software facilitates extensive reporting – enabling leadership teams to get an overall view of potential sanctions breaches, conflicts of interest, bribery attempts, and fraudulent activity at the touch of a button.

Implementing a GRC platform to manage these areas not only supports healthcare organisations to align with ethical standards, but it also safeguards the integrity of healthcare services, maintains public trust, and contributes to the overall effectiveness of the healthcare system.

If you would like to learn more about how the Camms platform could automate your processes across gifts & hospitality, sanctions checks, bribery & corruption, disclosures, and anti-money laundering, request a demo. Find out more about how the Camms GRC platform is helping healthcare organizations here.

Jonathan Lindhe

Head of Solutions

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