“Facilitation payments” (often called “grease payments”) are small bribes paid to government officials to accelerate routine, non-discretionary actions (like processing a visa or connecting a utility). While some jurisdictions historically viewed these as “minor,” the UK Bribery Act and FCPA have tightened restrictions significantly.
Forensic Review Steps:
- Ledger Keyword Scans: Searching the general ledger for suspicious descriptions like “consulting fees,” “commissions,” “miscellaneous expenses,” or “urgent processing fees.”
- Petty Cash Audits: Reviewing small-value cash disbursements that lack official receipts from a government agency.
- Third-Party Agent Review: Investigating “Intermediaries” or “Fixers” who are paid a lump sum to “get things done” in high-risk jurisdictions without providing a detailed breakdown of their expenses.
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