Welcome to our June Update
A note from our Steering Committee
Welcome to the June edition of the Bribery Prevention Network bulletin, continuing our commitment to supporting Australian businesses in preventing, detecting, and addressing bribery and corruption.
This edition brings significant developments for Australian business. The Australian Federal Police has released its new guideline on self-reporting and cooperation — a landmark development that sharpens the incentive for companies to act early and invest in prevention. The NACC’s Operation Pelican report offers a timely reminder of what’s at stake in procurement processes. And globally, the EU’s first unified Anti-Corruption Directive has entered into force, with direct implications for Australian companies operating in European markets.
We are also pleased to share that the BPN has published a new case study — developed in collaboration with the Australian Federal Police — on recognising the red flags of foreign bribery. Drawing on a real Australian prosecution, it walks through the indicators that were present and that effective due diligence could have surfaced. We hope it serves as a practical resource for training, board awareness, and risk assessment across your organisation.
Finally, we are also delighted to welcome Duxton Hill to the BPN Impact Committee. Duxton Hill brings a breadth of legal experience that will strengthen the network’s work, and we look forward to collaborating with them as we continue to build a business environment where bribery has no place.
As always, we encourage you to explore the full suite of free resources at briberyprevention.com.
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The Australian Federal Police has released its new Guideline: “Optimal investigation outcomes for self-reporting and cooperating corporations” — a landmark development that sharpens the incentive for companies to do the right thing.
Where a company self-reports, genuinely cooperates, and satisfies public interest considerations, the AFP will likely pursue a civil, non-conviction-based Proceeds of Crime Act resolution rather than criminal prosecution.
Three things stand out for boards, GCs and compliance teams:
- Cooperation has a quality test. Timeliness, full disclosure, LPP waivers, employee participation, and conduct in parallel investigations will all be scrutinised.
- Prevention has never mattered more. Tone from the top, adequate procedures, third-party due diligence and a genuine speak-up culture sit squarely inside the public interest assessment.
- Predictability is on offer. The AFP aims to conclude without-prejudice negotiations within 12 months, with resolutions made public via court orders and an AFP statement.
The message is clear: invest in prevention, build evidence of a strong compliance culture, and act fast when issues surface.
Find out more and read the guidance here.
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The National Anti-Corruption Commission (NACC) has released its report on Operation Pelican, a joint investigation with the AFP into a bribe from a company involved in a procurement process.
The investigation found that an employee of WSA Co Limited (WSA) (Western Sydney Airport) engaged in corrupt conduct by soliciting a $250,000 payment to influence the awarding of a contract. He was convicted in July 2025 and sentenced to two years’ imprisonment to be served in the community through an Intensive Correction Order including 500 hours of community service.
Operation Pelican highlights corruption risks associated with procurement, particularly where public officials interact with private companies competing for government contracts. The case reinforces the importance of strong governance, reporting mechanisms and ethical behaviour in identifying and responding to corruption risks.
Read the NACC’s report here, and explore more resources on due diligence here.
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The EU’s new Anti-Corruption Directive entered into force following Council adoption on 21 April 2026 — the bloc’s first unified anti-corruption framework. Member States now have 24 months to transpose it into national law. Key changes include:
- Harmonised offences across all 27 Member States — bribery (public and private), misappropriation, trading in influence, obstruction of justice, and enrichment from corruption
- Corporate fines of up to 5% of worldwide annual turnover (or €40 million) for core bribery offences
- Genuine, effective compliance programs explicitly recognised as a mitigating factor
The Directive’s reach is broad. Australian companies with EU subsidiaries or significant EU operations may be exposed — and fines are pegged to global turnover, not just EU revenue. A timely prompt to revisit your anti-bribery program.
Find out more here.
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New foreign bribery case study: Recognising the Red Flags
An Australian property developer sold an apartment complex to a foreign state-owned enterprise at an inflated value of A$22.6 million — with A$4.75 million channelled to foreign public officials through false invoices.
Developed with the Australian Federal Police, this case study highlights the red flags that due diligence could have surfaced. Read the blog and case study here.
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Do you have adequate procedures in place?
With the statutory review of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 anticipated later this year, now is the time to familiarise yourself with what adequate procedures look like in practice — before consultations begin.
The Attorney-General’s Department has published guidance across six principles. Explore BPN’s breakdown and supporting resources here.
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C-Suite Video Series — bribery prevention for senior leaders
Stay ahead of corruption risks with the BPN’s video series for C-suite executives and senior leaders. Learn why proactive policies, training, and monitoring are key to reducing risk; how global laws apply to your business; and why leadership commitment sets the ethical tone.
Watch the series here.
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Don’t miss the Bribery Prevention Network at the Australian Public Sector Anti-Corruption Conference (APSACC) in Canberra in September. Hear from BPN contributors in our panel: ‘Integrity at the public and private interface’, featuring:
- Andrew Wilcock, Managing Associate, Disputes and Investigations, Allens
- Harriet Tennent, Director, Forensic Financial Crime, KPMG
- Jeldee Robertson, Coordinator, Taskforce Solaris, Australian Federal Police
- Nigel Incoll, Executive Manager, Anti-Bribery & Corruption, Westpac Group
Register now: https://www.apsacc.com.au/
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The Bribery Prevention Network is a public-private partnership that brings together business, civil society, academia and government with the shared goal of supporting Australian business to prevent, detect and address bribery and corruption and promote a culture of compliance. Read more here.
This newsletter is created for the anti-bribery community, by the anti-bribery community. Do you have news or stories to contribute to our next edition? Contact us at [email protected]
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