Case studies

Real-life Australian foreign bribery prosecution

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This document outlines a real-life case study of an organisation engaging in foreign bribery while operating in a high-risk jurisdiction.


The facts described have been distilled from a recent real-life conviction of a company for foreign bribery in the NSW Supreme Court and Court of Criminal Appeal.

After the case study, some general principles are outlined on how to effectively prevent, detect and address foreign bribery.

Finally, some questions are posed which invite the reader to consider how the case study could be used to test their own foreign bribery controls. Readers are encouraged to reflect on the example provided, and on how this example may be useful for the reader in mitigating bribery risks in their own organisation.

The Bribery Prevention Network acknowledges the pro-bono contribution of Allens in developing this case study.

Relevant resources

This guide from the Australian Federal Police sets out the importance of self-reporting and the practical steps for companies to self-report possible criminal conduct. It covers when to report, what information to include in the report, and the AFP's investigation process.

Self-reporting is a significant first step in addressing suspected foreign bribery. This Guideline is designed to provide companies with information about how self-reporting will be taken into account by the CDPP when determining whether or not to commence a prosecution, and highlights the reasons why a company may choose to self-report including to comply with directors’ duties and limit liability. Information about early guilty pleas is also provided.

When allegations of fraud or corruption arise, it is important to undertake a prompt and thorough investigation. This short 'how to' guide outlines the key steps to make an investigation effective. Be sure to also consider the 'whistleblowing' section of this site for more recent developments in obligations relating to whistleblowers.

Ranks 180 countries and territories by their perceived levels of public sector corruption. Helps companies to understand and compare the corruption risks of operating in different countries. Useful for undertaking third party risk analysis and due diligence. Learn about regional trends, and the areas that have the greatest bribery and corruption risks.