In December 2025, the International Foreign Bribery Taskforce (IFBT) published a list of indicators of foreign bribery to assist organisations and those working in high-risk sectors to better prevent, detect and address potential incidents of foreign bribery.

The IFBT comprises the Australian Federal Police (AFP), the Federal Bureau of Investigation, United Kingdom (UK) National Crime Agency, UK Serious Fraud Office, New Zealand (NZ) Serious Fraud Office, NZ Police and the Royal Canadian Mounted Police.

On their own, these indicators do not necessarily mean that foreign bribery or corruption is occurring. However, when considered in conjunction with one another and within context, it suggests further assessment and awareness is warranted.

The following case study illustrates how common indicators of foreign bribery can converge and how the indicators can be used in early detection of foreign bribery.

Case Study

An Australian property developer was investigated for allegations of foreign bribery in relation to the sale of newly developed apartment complex. The property was sold to a foreign state-owned enterprise for A$22.6m, inflated from its true value of AU$17.85m.

AUD $4.75 million in funds from the inflated sale were distributed to foreign public officials. False invoices were made out for ‘consultancy and advisory fees’, ‘advertising and promotions’, as well as ‘marketing and professional advice.’

The developer was charged with foreign bribery and multiple false accounting offences and about AU$1.6 million in assets were restrained. Each offence charged carried a maximum penalty of 10 years imprisonment.

The developer ultimately plead guilty to rolled up charges of false accounting and was given a suspended sentence of 21 months imprisonment.

Unpacking the indicators

In many bribery cases, third-party agents or intermediaries are used to distance an individual or organisation from illicit payments, often under the guise of “consultancy” or “advisory” services.

Additional warning signs include:

• The regular creation of short-lived companies with no genuine business purpose
• Large, unexplained payments to overseas third parties
• Payments routed through offshore accounts or shell companies
• Requests to make payments to unrelated or third-party accounts

Foreign bribery risk increases significantly when business activity involves foreign government contracts or state-owned entities. Companies are exposed to individuals entrusted with prominent public functions, commonly referred to as Politically Exposed Persons (PEPs), who may be in positions to improperly influence outcomes. Unmonitored or frequent contact with PEPs where there is no clear oversight is a key risk factor.

Another major warning sign is the use of high-risk jurisdictions, including links to countries with high Tax Haven or Corruption Perception Index scores.

The above case study also highlights red flags related to:

• Incorporation in a country with no real connection to that country
• Links to PEPs who hold foreign assets, such as overseas real estate
• Corporate structures spanning multiple jurisdictions.

Why This Matters

When business involves foreign government contracts or government-owned entities, the risk of bribery increases significantly.

Early recognition of the indicators, effective due diligence and strong compliance controls are essential safeguards against legal, financial, and reputational harm for organisations.

The Bribery Prevention Network acknowledges the contribution of the Australian Federal Police in developing this blog post and case study.