Anti-Corruption and Anti-Bribery

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APPENDIX 5-D: Common Red Flags Indicating Heightened Potential for Corruption

Lack of written agreement or nonstandard written or needlessly complex agreement

High commissions or unusually large fees for the work, region, or deal

Specific third party required or recommended by party to agreement

Lack of experience, resources, or staff to support type of vendor work/engagement

Third party does not appear to be a legitimate company or has been in existence for less than one year; no independent references

Third party is a (or is related to) government official or promotes its connections to government

Insufficient due diligence (governmental relationship, credit, experience) or lack of cooperation in due diligence

Third party appears in negative news or is subject of a government investigation or enforcement action or references illegal activities

Payments into offshore accounts or to locations not related to the deal

Use of petty cash or other poorly documented/loosely tracked slush funds (e.g., marketing funds)

Inadequate, generic, or otherwise questionable descriptions of activities, requests for changes to invoices, or documents

Missing or incomplete documentation

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