What is Bribery?
Bribery is the act of offering, giving, receiving, or soliciting something of value — money, gifts, services, or favors — with the intent to influence the actions, decisions, or conduct of a person in a position of authority or trust.
Legal frameworks prohibiting bribery
- FCPA (US): prohibits US companies and their agents from paying foreign government officials to obtain or retain business; accounting provisions require internal controls sufficient to prevent and detect bribery
- UK Bribery Act: the world's strictest anti-bribery law — prohibits both public and private sector bribery, and holds companies liable for bribery by associated persons unless adequate prevention procedures exist
- Sapin II (France): requires companies with >500 employees and >€100M revenue to implement mandatory anti-corruption programs, including third-party due diligence, accounting controls, and anonymous reporting
Active vs. Passive Bribery
Active bribery is the act of offering or paying a bribe (the corruptor side). Passive bribery is the act of soliciting or accepting one (the corrupted side). Both are criminal offenses in most jurisdictions.
Internal controls against bribery
Effective anti-bribery controls address both governance (code of conduct, training, third-party due diligence) and transaction monitoring — detecting suspicious payments to agents, unusual T&E claims, round-amount disbursements in high-risk jurisdictions. Transaction-level analytics on 100% of payments is the most reliable detection method.
Bribery and Supervizor
Supervizor applies pre-built bribery detection controls across payment and expense processes — flagging agent payments without proper documentation, unusually large hospitality expenses, and disbursement patterns in jurisdictions flagged by regulators. The compliance solution supports Sapin II surveillance obligations directly.
Related Supervizor pages
→ Compliance — Sapin II and FCPA control testing
→ AI & Controls — anti-corruption transaction monitoring