FCRM - Financial Crime Risk Management

Bribery

Red-Flags

Example activities which on their own, or when combined with other red-flags, might be indicative of bribery risk, involving benefits or payments (or offers to pay) made with the intention of causing someone to act dishonestly or corruptly:

Unusual cash payments, made via single or multiple transactions
Unexplained urgency or pressure exerted to advance payment
Payments made ahead of schedule or against ambiguous (or non-existent) contractual terms
Payments routed via a third party for no apparent reason, or where supporting payment vouchers/journals lack transparency
Unusual commission arrangements involving intermediaries or agencies that lack transaparent association with relevant deals/transactions
Unexplained or poorly documented meetings held with favoured contractors or suppliers in a competitive bid arrangement
Lavish gifts being offered or received
Budget holders or payment signatories applying unusual restrictions on communications with contractors, providers or suppliers

More red-flags

Compliance

An effective Compliance Programme reduces corruption risk when designed to prevent and detect violations or breaches before they occur. Such programmes include:

Tone from the top - High level Policy Statement or Code of Conduct endorsed by senior management.
Guidance - Compliance Manual with written standards and guidelines for all employees, contractors, agents, etc,.
Accountabilty - Designated senior manager responsible for oversight, monitoring and compliance arrangements.
Education - Training and awareness for directors, management, employees and relevant contractors / agents.
Alert mechanism - Confidential telephone hotline for reporting details of suspected breaches.
Assurance - Independent reporting to Senior Management (i.e. The Board) and the Audit Committee (e.g. Results of Internal Audit reviews/compliance-based testing).