International Foreign Bribery Taskforce indicators of foreign bribery
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How to spot foreign bribery
Below are some key indicators that a person or company may be accepting or soliciting bribes. The indicators can help people in high-risk sectors, and the broader public, to recognize possible foreign bribery and report it.
The indicators
There is no one indicator of foreign bribery, there are many. If a person or a business demonstrates multiple indicators, it's a red flag. Individuals and companies exhibiting the indicators are more likely to engage in corrupt practices. Some indicators are also common to other financial crimes, including money laundering.
Indicators do not automatically equate to criminal activity. They are factors that signal an individual or business may be compromised. They can suggest further evaluation or assessment is warranted. Or they may demonstrate that conduct has moved beyond legitimate business or financial practices. Members of the public are encouraged to contact their local police if they suspect bribery. Report it to the RCMP's International Anti-Corruption Team (reporting page below) if it involves:
Conduct indicators
- Uses third party agents or consultants
- Applies multiple aliases or records name inconsistently across datasets
- Utilises shell companies
- Provides or uses multiple email addresses across different domains
- Regularly creates new companies or businesses which are only registered, or registered in their name, for a short time
- Makes unexplained large payments to overseas third parties or consultants
- Makes payments to offshore accounts or shell companies
- Engages in transactions with vague or non-existent documentation
- Deals with inflated invoices or overpays for services
- Makes offshore cash transactions or is linked to requests for cash payments
- Business partners or agents refuse to provide details on transactions
- Is linked to requests to make payments through third parties or to unrelated accounts
- Requires unusual secrecy in relation to transactions or contracts and is reluctant to share financial records regarding same
- Requests a high level of discretion around a particular contract
- A Politically Exposed Person (PEP) requests additional fees
- A third-party agent or consultant requests additional fees without explanation
- Foreign contracts are awarded without a competitive bidding process
- Contracts are awarded to a party that lacks the capability to fulfil them
- Foreign agents or consultants are hired without proper due diligence
- Excessive gifts, travel or hospitality are given to Politically Exposed Persons (PEPs)
Note
- Politically Exposed Person (PEP)
- An individual entrusted with prominent public functions, it can include government officials, military officers, judges and high-ranking executives of state-owned enterprises.
Government affiliation indicators
- Business involves foreign government contracts
- Requires foreign government permits, approvals or licenses to undertake or operate business
- Is involved in lobbying foreign governments for legislative change
- Employs or contracts PEPs in foreign countries of operation
Country link indicators
- Has links to a country with a Corruption Perception Index score below 40
- Has links to a country with a Tax Haven Index greater than 70
- Has links to a country with a Financial Secrecy Index score greater than 75
- Has links to a country with a citizenship or visa by investment provisions (golden passport/golden visa)
- Has links to a PEP linked to a foreign company
- Has links to a PEP who owns real estate in a foreign country
- Has three or more passports from multiple countries
- Incorporated in a country with no real connection to that country
- Operates in a net export country
Ownership indicators
- Owns property through a trust
- Owns a business that doesn't align with their occupation
- Owns multiple properties without a mortgage or with a shorter mortgage
- Owns, buys or stores high-value assets in a foreign country
- Owns cryptocurrency
- Has a high-value property portfolio disproportionate to income
- Has a high-value property portfolio disproportionate to company size
- Purchases assets from government below market rate
- Has limited identifiable assets in their name, however immediate family has significant assets
- Owns real estate overseas
- Owns shares/companies through complex structures
- Is a shareholder in a company through layers of complex company ownership
- Owns property through trusts or transfers property through trusts
- Owns assets purchased from a foreign government
- Is a bespoke charity buying property
Registration information indicator
- Charity registered with the same name as company
- Is on, or linked to entities on, debarment, banned list or sanctions list
- Changes between industries
- Is a shell company or uses shell companies
- Business description does not align with office holders' occupation
Other associations
- Is a PEP, or has links to a PEP, whose wealth greatly exceeds their public service salary
- Has a criminal history or adverse reporting including in relation to foreign bribery allegations
- Is associated with a profession known to facilitate crime
- Is a PEP, or has links to a PEP, associated with entities linked to high-risk industries
- Is linked to a person on a debarment list, banned list or sanctions list
- Is associated with multiple trusts
- Is associated with a bespoke or project specific charity
- Has links to companies across multiple different industries
- Has links to a PEP in a high-risk country that has school aged children attending an offshore private school
- Has frequent unmonitored interactions with a PEP or PEPs
What we would like you to do
If you identify activity which may indicate foreign bribery, please report it to the appropriate authority. It can be reported to the authorities in your jurisdiction and/or in the jurisdiction of the people or companies involved.
Links to report foreign bribery include:
Other jurisdictions will have similar reporting avenues available to the public. Consult law enforcement or anti-corruption agencies within your jurisdiction for advice.
The International Foreign Bribery Taskforce
The above indicators were developed by the International Foreign Bribery Taskforce (IFBT). The RCMP, the Australian Federal Police, New Zealand Police, New Zealand Serious Fraud Office, the National Crime Agency of the United Kingdom, the United Kingdom Serious Fraud Office and the United States Federal Bureau of Investigations all work together on the IBFT.
The IFBT brings together foreign bribery specialists to share intelligence, knowledge, skills, methodologies and case studies in international bribery investigations. To learn more about the IBFT, indicators of foreign bribery, and the relevant legislation for each partner country visit this page.
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