Corruption Indicators

The SFO has produced a list which is not exhaustive but at least it demonstrates some of the behaviour the SFO will be interested in. They will have regard to:

• abnormal cash payments
• pressure exerted for payments to be made urgently or ahead of schedule
• payments being made through a third party country – for example, goods or services supplied to country ‘A’ but payment is being made, usually to a shell company in country ‘B’
• an abnormally high commission percentage being paid to a particular agency. This may be split into two accounts for the same agent, often in different jurisdictions
• private meetings with public contractors or companies hoping to tender for contracts
• lavish gifts being received
• an individual who never takes time off even if ill, or holidays, or insists on dealing with specific contractors himself or herself
• making unexpected or illogical decisions accepting projects or contracts
• the unusually smooth process of cases where an individual does not have the expected level of knowledge or expertise
• abuse of the decision process or delegated powers in specific cases
• agreeing contracts not favourable to the organisation either because of the terms or the time period
• unexplained preference for certain contractors during tendering period
• avoidance of independent checks on the tendering or contracting processes
• raising barriers around specific roles or departments which are key in the tendering or contracting processes
• bypassing normal tendering or contracting procedures
• invoices being agreed in excess of the contract without reasonable cause
• missing documents or records regarding meetings or decisions
• company procedures or guidelines not being followed
• the payment of, or making funds available for, high value expenses or school fees (or similar) on behalf of others.