The U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act (UKBA), Sapin II and many other Anti-Bribery and Corruption (ABC) laws and regulations around the world make it clear that bribery and corruption is prohibited, illegal and the source of fines, penalties, reputational damage, and in some cases criminal liability. This is particularly true when the bribes are offered to foreign government officials, especially by third parties.
Use this document to identify when bribery and corruption activities are most likely to be occurring within your business. Next to each bribery and corruption ‘red flag’ we have provided some suggested responses and best practices an organisation can use to address these issues and minimize the risks for your business.
- What procedures should I have in place for third party engagements?
- Are there particular red flags that indicate increased corruption risk?
- How should I respond to high-risk third-party red flags?