Frequently Asked Questions  - FAQs

Section A: For institutions and boards

What is the purpose of the CACE?

The certified anti-corruption entity (CACE) is designed to measure institutional corruption exposure arising from how decision-makers understand and reason about corruption risk when exercising authority.

CACE does not certify integrity, compliance, or governance quality. It provides a structured, non-comparative diagnostic insight into exposure at a specific point in time.

Is CACE a certification of ethical conduct or good governance?

No.

CACE does not certify ethical behavior, integrity, governance effectiveness, or compliance with laws or standards. It does not attest to the absence of corruption or misconduct.

CACE quantifies exposure based on decision-maker anti-corruption knowledge intelligence. Nothing more. Nothing less.

How is CACE different from audits, compliance reviews, or ESG assessments?

Audits, compliance reviews, and ESG assessments primarily examine:

• the existence and design of controls,

• policy compliance,

• and reported practices.

CACE examines something different:
whether those who exercise authority possess and apply the anti-corruption knowledge required to recognize corruption risk when making or overriding decisions.

CACE complements existing mechanisms. It does not replace them.

What is the corruption prevention management test (CPMT)?

The CPMT is the assessment instrument used within the CACE process. It is a formal, proctored examination designed to evaluate anti-corruption knowledge intelligence among decision-makers.

The CPMT is not training, awareness testing, or professional certification. It is used exclusively for institutional exposure assessment.

Does holding professional certifications improve CACE or CPMT results?

Not by itself.

While CPMT domains overlap conceptually with recognized anti-corruption frameworks and professional knowledge bases, CPMT does not assess recall, training exposure, or possession of credentials.

CPMT evaluates how corruption risk is reasoned about at the level of authority. An organization may employ highly qualified professionals and still exhibit elevated exposure if corruption-critical decisions are taken or overridden elsewhere.

Are individual CPMT results disclosed?

No.

Individual results are confidential and are not disclosed to the organization, regulators, or third parties. CPMT results are aggregated and interpreted at the entity level only.

Are CACE results public?

No, by default.

CACE outcomes are private. The AACI does not publish rankings, scores, or public registries.
Any public reference to CACE status is controlled and subject to disclosure guidelines.

When CACE is recognized or adopted by a regulator, disclosure requirements may be addressed separately by agreement and in accordance with applicable law.

Does CACE provide a pass or fail result?

No.

CACE does not produce pass/fail outcomes, ratings, or comparative scores. It provides an exposure profile that must be interpreted in context.

How often should an organization undertake CACE?

CACE is a point-in-time assessment.

Because decision-maker composition and knowledge intelligence change over time, annual reassessment is generally considered methodologically appropriate. Where required, assessment frequency may be aligned with regulatory or supervisory frameworks.

Is CACE currently available for engagement?

CACE is offered subject to The AACI’s readiness, eligibility criteria, and formal contractual agreement.

Institutional briefings may be requested. Formal engagements commence only once all procedural, governance, and logistical requirements are satisfied.

Who is CACE designed for?

CACE is designed for institutions whose boards, senior leadership, and other decision-makers who exercise material decision-making authority treat corruption exposure as a governance responsibility, not a reputational exercise.

It is not designed for marketing certification, ESG signaling, or cosmetic validation.

What does an organization benefit from the CACE?

An organization benefits from CACE by gaining a structured, evidence-based understanding of its institutional corruption exposure as it arises from decision-maker anti-corruption knowledge intelligence.

Specifically, CACE enables organizations to:

• identify governance-level blind spots that are not visible through audits or compliance reviews,

• understand how decision-making practices may unintentionally create corruption exposure,

• support board-level discussions with a disciplined, non-anecdotal diagnostic, and

• strengthen oversight by focusing attention on how authority is exercised, rather than assuming risk is managed through policies or credentials.

CACE does not provide reassurance. It provides governance clarity.

What do regulators benefit from the CACE?

Regulators benefit from CACE as a non-intrusive diagnostic reference that complements, rather than replaces, supervisory and enforcement tools.

CACE offers regulators:

• conceptual transparency into how institutions assess corruption exposure at the decision-maker level,

• a structured approach to understanding governance-related risk without requiring disclosure of proprietary mechanics,

• an instrument that does not interfere with regulatory judgment or enforcement discretion, and

• a basis for dialogue focused on governance capability rather than formal compliance alone.

CACE does not substitute regulatory supervision. It supports more informed supervisory engagement.

What would a stock exchange regulator or financial sector regulator gain from requiring CACE?

When adopted by a stock exchange regulator or financial sector supervisor, CACE can serve as a governance-focused diagnostic requirement that addresses a persistent supervisory gap.

Such regulators may benefit by:

• introducing a standardized, non-comparative method to assess corruption exposure across regulated entities,

• shifting attention from rule compliance to decision-maker capability and judgment,

• encouraging boards to engage substantively with corruption risk rather than delegating it downward, and

• reinforcing market integrity by promoting informed governance without mandating specific controls or structures.

CACE does not impose uniform solutions. It provides a consistent lens through which exposure can be understood and addressed.

Does requiring CACE replace existing regulatory or compliance obligations?

No.

CACE is not designed to replace regulatory requirements, internal controls, audits, or compliance programs. It does not alter legal obligations or enforcement standards.

Any regulatory adoption of CACE would operate alongside existing frameworks, focusing specifically on governance-level anti-corruption knowledge intelligence and decision-making exposure.

Section B: For regulators and supervisory authorities

What is the supervisory relevance of the certified anti-corruption entity (CACE)?

CACE is a governance-focused diagnostic instrument that measures institutional corruption exposure arising from decision-maker anti-corruption knowledge intelligence. Its relevance to supervision lies in its focus on how authority is exercised, rather than on the formal existence of controls, policies, or training programs.

CACE does not assess compliance with laws or regulations, nor does it substitute for regulatory judgment. It may, however, support supervisory dialogue by highlighting governance-level exposure that is not typically visible through traditional supervisory tools.

Does CACE interfere with regulatory supervision or enforcement?

No.

CACE is designed to be non-intrusive and non-determinative. It does not interfere with supervisory processes, inspections, investigations, or enforcement actions. It does not constrain regulatory discretion or introduce alternative compliance standards.

CACE outcomes do not bind regulators and do not create expectations of regulatory reliance or deference.

Does CACE create any form of regulatory safe harbor or mitigation expectation?

No.

CACE does not provide a safe harbor, mitigation credit, or enforcement shield. Completion of the CACE process does not affect regulatory obligations, liability assessments, or enforcement outcomes.

CACE is a diagnostic instrument. It does not certify conduct, compliance, or integrity.

How does CACE differ from regulatory assessments, inspections, or examinations?

Regulatory assessments and inspections typically evaluate:

• compliance with applicable laws and rules,

• adequacy of controls and systems,

• adherence to supervisory expectations.

CACE evaluates something different:
whether those who exercise authority demonstrate the anti-corruption knowledge intelligence required to recognize and reason about corruption risk when making or overriding decisions.

The two approaches are complementary but not interchangeable.

Does CACE require disclosure of results to regulators?

No, by default.

CACE outcomes are private. There is no public registry, ranking, or mandatory disclosure. Any disclosure to a regulator occurs only:

• at the discretion of the assessed entity, or

• pursuant to a specific regulatory framework or agreement, and

• in compliance with applicable law.

Does CACE use comparative scoring or benchmarking across entities?

No.

CACE is non-comparative. It does not produce rankings, league tables, peer comparisons, or sector scoring. Results are interpreted within the context of the assessed entity only.

This design avoids market distortion and reputational signaling concerns.

Does CACE rely on proprietary or opaque methodologies?

CACE and the underlying corruption prevention management test (CPMT) are governed by proprietary methodologies developed and administered by The American Anti-Corruption Institute (AACI).

While detailed mechanics are not publicly disclosed, the scope, intent, and limits of the assessment are transparent. This balance is intended to protect methodological integrity without impeding supervisory understanding.

Under what conditions could a regulator reference or adopt CACE?

Any regulatory reference to or adoption of CACE would occur only by explicit agreement, subject to:

• the regulator’s legal authority,

• applicable statutory and supervisory frameworks,

• and jurisdiction-specific requirements.

CACE is not designed to mandate specific governance structures, controls, or outcomes. It provides a consistent diagnostic lens, not a regulatory prescription.

Does CACE replace or reduce the need for regulatory oversight?

No.

CACE does not replace supervision, inspections, or enforcement. It does not alter the regulator’s role, authority, or tools.

CACE may support more informed governance-focused dialogue, but regulatory oversight remains independent and paramount.

What safeguards exist to prevent misuse of CACE in a regulatory context?

Safeguards include:

• explicit limits on what CACE does and does not assess,

• prohibition of comparative or public scoring,

• controlled disclosure posture,

• and contractual and governance mechanisms governing use of outcomes.

Any attempt to misrepresent CACE outcomes as regulatory endorsement or compliance validation is considered misuse.

Why would a regulator engage with CACE conceptually?

Regulators increasingly recognize that corruption failures often occur despite formal compliance with laws, rules, and control frameworks. CACE provides a structured, governance-focused way to examine a dimension that is frequently implicated in enforcement actions but rarely assessed beforehand: decision-maker anti-corruption knowledge intelligence.

Any regulatory engagement with CACE is therefore conceptual and diagnostic, not substitutive or delegative. CACE does not alter supervisory authority, replace regulatory instruments, or redefine regulatory expectations. It is designed to coexist with supervisory frameworks, not to replicate or replace them.

Section B1: For stock exchange regulators

How is CACE relevant to market integrity and listed entities?

For stock exchange regulators, CACE is relevant as a governance-focused diagnostic that examines how corruption risk is understood and managed at the level of authority within listed entities.

CACE does not assess disclosure compliance, listing rules, or market conduct. Its relevance lies in highlighting governance-level exposure that may affect market integrity indirectly through anti-corruption failures in decision-making rather than through disclosure breaches.

Does CACE create any form of listing qualification or reputational signal?

No.

CACE does not constitute a listing requirement, qualification, rating, or market signal. It does not certify governance quality, ethical conduct, or compliance with listing obligations.

Any reference to CACE by a listed entity is controlled and subject to disclosure guidelines to avoid market misinterpretation.

Could CACE be used as a disclosure or reporting requirement?

CACE is not designed as a disclosure instrument.

Any consideration of CACE within disclosure or reporting frameworks would depend entirely on the stock exchange regulator’s legal authority, policy objectives, and applicable rules. CACE itself does not prescribe disclosure, nor does it generate public or comparative outputs.

Does CACE affect investor protection or transparency requirements?

No.

CACE does not alter investor protection standards, transparency obligations, or disclosure regimes. It does not replace or supplement statutory reporting requirements.

Its function is diagnostic and internal, focusing on governance capability rather than public reporting.

How does CACE avoid creating misleading market comparisons?

CACE is explicitly non-comparative. It does not produce rankings, peer benchmarks, or scores for market positioning.

This design avoids distortions, reputational signaling, or selective disclosure that could affect market fairness.

Under what circumstances might a stock exchange regulator engage with CACE conceptually?

A stock exchange regulator may engage with CACE conceptually where there is interest in:

• governance resilience of listed entities,
• the extent to which anti-corruption knowledge intelligence is present at the level of organizational authority, or
• systemic governance weaknesses that are not captured by disclosure-based oversight.

Such engagement would be informational and conditional, not substitutive or mandatory.

Section B2: For banking and financial sector supervisors

How is CACE relevant to prudential supervision?

For banking and financial sector supervisors, CACE is relevant as a governance diagnostic that focuses on decision-maker anti-corruption knowledge intelligence related to corruption risk.

It complements prudential supervision by examining a dimension frequently implicated in enforcement actions: how authority is exercised when corruption risk intersects with commercial, operational, or strategic decisions.

Does CACE assess risk culture or internal control effectiveness?

CACE does not assess risk culture, internal control effectiveness, or compliance frameworks in the supervisory sense.

Instead, it evaluates whether those who exercise authority demonstrate the anti-corruption knowledge intelligence required to recognize corruption exposure when controls are overridden, weakened, or relied upon without sufficient judgment.

Does CACE overlap with fit-and-proper or senior management assessments?

No.

CACE does not assess individual fitness, propriety, integrity, or competence for regulatory approval purposes. It does not replace or inform fit-and-proper determinations.

CACE operates at the institutional exposure level, not at the individual regulatory suitability level.

Could CACE be integrated into supervisory review processes?

Any integration would be entirely subject to the supervisor’s legal framework and discretion.

CACE is not designed to be embedded automatically into supervisory review processes. Where referenced, it would serve as a supplementary diagnostic input, not as a supervisory metric or determinant.

Does CACE affect enforcement or remedial actions?

No.

CACE outcomes do not influence enforcement decisions, remedial actions, capital requirements, or supervisory ratings. They do not create mitigation, aggravation, or reliance effects.

Supervisory judgment remains independent and paramount.

Why might a banking or financial supervisor consider CACE conceptually?

Banking and financial supervisors increasingly observe that corruption-related failures often arise despite formal compliance, control, and risk management frameworks. These failures are frequently linked to how authority is exercised in practice, rather than to the absence of rules or controls.

CACE provides a structured, governance-focused way to examine whether anti-corruption knowledge intelligence is present at the level of organizational authority, and whether it is sufficient to recognize and manage corruption exposure under real-world decision-making conditions. This perspective may inform supervisory dialogue and understanding without constraining supervisory judgment or altering supervisory powers.

CACE is a diagnostic governance instrument, not a prudential tool. It is designed to coexist with supervisory frameworks, not to redefine, replace, or supplement prudential supervision, enforcement, or regulatory decision-making.