The UK’s Serious Fraud Office working with law enforcement partners across the Five Eyes nations (an intelligence alliance consisting of Australia, Canada, New Zealand, the UK and the US), has published guidance to help professionals and the public identify potential indicators of foreign bribery. I counted over 60 indicators in total. These were categorised into:
- Conduct.
- Government affiliations.
- Country links.
- Ownership.
- Registration information.
- Other associations.
There are some here that will be fairly obvious to most people on this forum like owning property through trusts or “Is on, or linked to entities on, debarment, banned list or sanctions list”. Others are in my view less obvious such as “Owns multiple properties without a mortgage or with a shorter mortgage” and “Has links to a PEP in a high-risk country that has school aged children attending an offshore private school”.
A number of these indicators may be of interest to those of you who wrangle with large data sets including:
- “Owns a business that doesn’t align with their occupation”.
- “Business description does not align with officeholders’ occupation.”
- “Charity registered with the same name as company”
- “Changes between industries”
- “Is associated with multiple trusts”
- “Is a PEP, or has links to a PEP, associated with entities linked to high-risk industries”
There are some definitions in the glossary section at the end including “shell company” but not all terms are defined for example there is no definition of “high-risk industries” within the publication.
Serious Fraud Office and Five Eyes on foreign bribery indicators - GOV.UK (UK Government news)
https://www.afp.gov.au/crimes/fraud-and-corruption/foreign-bribery-and-grand-corruption (full document)
