Focus area · ABC
Bribery and corruption risk, mapped to your countries and sectors
Where do your staff, agents and partners meet public officials, state-owned customers and discretionary decisions, and how have authorities punished bribery there? We map the exposure country by country and sector by sector, with a source for every finding.
Why exposure differs so much
Bribery risk is rarely uniform. It concentrates where licences, permits, customs clearance, public tenders and state-owned customers meet intermediaries with discretion over payments. The same company can face low exposure in one market and acute exposure in the next.
Several regimes reach beyond their home jurisdiction. US, UK and French law can apply to conduct abroad, and German criminal law covers bribery of foreign public officials. An assessment has to show which regimes bite on your footprint and how actively they are enforced.
Legal frameworks we map
We map the regimes that apply to your footprint. Typical anchors:
- US Foreign Corrupt Practices Act (FCPA)
- Anti-bribery and accounting provisions with extraterritorial reach for issuers, domestic concerns and conduct on US territory. DOJ enforcement priorities shifted in 2025; we track how current policy translates into actual cases.
- UK Bribery Act 2010
- Offences of bribing, being bribed and bribing a foreign public official, plus the corporate offence of failing to prevent bribery (section 7), with adequate procedures as the only defence.
- France: Sapin II
- Loi n° 2016-1691 requires larger companies to run an anti-corruption programme that includes a risk map. The French Anti-Corruption Agency (AFA) audits compliance.
- Germany: StGB §§ 299 ff. and §§ 331 ff.
- Bribery in commercial practice (§ 299), bribery of public officials (§§ 331–335) and the extension to foreign and international officials (§ 335a); corporate fines under §§ 30, 130 OWiG.
- Local anti-corruption laws
- The national statutes of each country in scope, including procurement rules, gift and hospitality thresholds for officials and any corporate-liability regime.
- International conventions
- The OECD Anti-Bribery Convention and UNCAC as the frame for how seriously a country's authorities pursue foreign bribery.
This is a risk analysis, not legal advice. Where a finding raises a legal question, we say so and you take it to counsel.
What we look at
External analysis
Your exposure as the outside world sees it.
- Statutes, thresholds and extraterritorial reach per country
- Enforcement record of the competent authorities (e.g. DOJ, SEC, SFO, PNF, German public prosecutors)
- Bribery cases, settlements and debarments in your sector
- Cases at your direct competitors
- Indicators such as the Corruption Perceptions Index, read with their limits
Internal analysis (under NDA)
Your exposure as your own data shows it.
- Internal investigations and hotline cases with a bribery dimension
- Agents, distributors and consultants by country, role and remuneration
- Sponsorships, donations and memberships with links to officials
- Gifts, hospitality and meals involving public officials
Seven focus areas, mapped against every source we read.
| Module 1 · External analysis | Module 2 · Internal analysis (NDA) | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Focus area | Law & regulation | Enforcement record | Sector cases | Competitor cases | Indicators | Internal cases | Business partners | Sponsoring, donations, memberships | Gifts & hospitality |
| ABCAnti-bribery & corruption | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source |
| AMLAnti-money laundering | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Where relevant | Not used |
| ATRAntitrust & competition | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Core source | Where relevant |
| FRDFraud | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Where relevant |
| PRVData privacy | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Not used | Not used |
| EXCExport control & sanctions | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Not used | Not used |
| HRTHuman rights | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Not used |
Highlighted row: ABC · Anti-bribery & corruption
Typical red flags
- Success fees or commissions out of proportion to the service rendered
- Intermediaries recommended or required by a public official or state-owned customer
- Payments in cash, to offshore accounts or to parties other than the contracting party
- Licensing, permit or customs problems that resolve abruptly
- Sponsorships and donations to organisations linked to decision-makers
- Hospitality for officials above local thresholds or extended to family members
- Competitors in the same market that settled for similar conduct
Sources
- Enforcement releases and settlement documents from authorities (e.g. DOJ, SEC, SFO, PNF, AFA)
- Court records and published judgments where available
- Debarment lists of multilateral development banks
- Reputable press and investigative journalism, cross-checked against primary sources
- Transparency International CPI and World Bank governance indicators: perception and governance measures, not measures of your exposure
Every finding in the report carries its source and date.
Typically exposed sectors
Exposure tends to be higher where business depends on public contracts, licences and state-owned customers, or relies heavily on sales intermediaries.
A tendency, not a rating. Your actual exposure depends on business model, customer mix and footprint.
In your deliverable
- PDF: a bribery and corruption chapter with legal map, enforcement picture, sector and competitor cases, red flags and recommended measures
- Heatmap row per country × sector with the likelihood × impact rating
- XLSX: case register (authority, year, company, conduct, sanction, source), indicator table and scoring sheet
- With the internal module: the combined view, e.g. intermediaries concentrated in high-exposure markets
Questions on bribery and corruption
Isn't the Corruption Perceptions Index enough to rank our countries?
No. The CPI measures perceived public-sector corruption at country level. It says nothing about your sector, your customers or the intermediaries you use. We use it as one input and state its limits next to it.
How does this relate to an investigation or a legal opinion?
It comes before them. The analysis shows where exposure sits and why. It is neither an investigation of individual conduct nor legal advice; if findings call for either, we say so.
Can you screen our agents and distributors?
In the internal module we analyse your third-party population by country, sector, role and payment profile and show where exposure concentrates. Due-diligence reports on individual named partners are a separate exercise; the analysis tells you which partners would warrant one.
Map your bribery exposure.
Tell us your countries, sectors and the decision you are preparing. We come back with a scope proposal.