Bribery & Facilitation Payments
Corporate bribery and facilitation payments disguised as legitimate business spend. Common forms include inflated or fictitious consultancy and intermediary fees, round-sum payments to agents in high-risk jurisdictions, and success fees that lack commercial substance and are used to channel improper payments to officials or counterparties.
What it is
Corporate bribery and facilitation payments disguised as legitimate business spend. Common forms include inflated or fictitious consultancy and intermediary fees, round-sum payments to agents in high-risk jurisdictions, and success fees that lack commercial substance and are used to channel improper payments to officials or counterparties.
Control objective
Detect payments to intermediaries, consultants, and agents that lack commercial rationale or proportionality and may constitute bribery or facilitation payments, including those structured to obscure the ultimate recipient.
Data required
- Payment purpose, narrative, and supporting documentation
- Counterparty type (agent, consultant, intermediary) and registration
- Payment jurisdiction and corruption-risk rating of recipient location
- Contract value versus services rendered (proportionality)
- Round-sum and success-fee payment indicators
- Beneficial ownership of recipient consultancy or intermediary entities
- Customer sector exposure (extractives, construction, defence, public contracts)
- Historical payment baseline to the same counterparty
Related typologies (Bribery & Corruption)
PEP & Grand Corruption Proceeds
Laundering the proceeds of grand corruption through or on behalf of politically exposed persons. Funds typically move through shell company layers, nominee arrangements, family members and close associates, and are placed into high-value assets such as real estate, luxury goods, and investment portfolios to obscure illicit origin.
State-Linked Infrastructure Corruption
Politically connected individuals and their associates extract bribes and kickbacks from construction and infrastructure contracts awarded by state or quasi-state entities. Proceeds flow through intermediary consultants, inflated invoices and nominee corporate structures before being layered into the financial system, often passing through private banking accounts and cross-border transfers before integration into apparently legitimate assets.