Bribery and improper payments
Early identification of communications suggesting payments, favors or benefits to influence decisions of third parties, public officials or client employees.
Linguistic warning signals
- references to unusual 'commissions' or 'expenses' outside process
- coordination of payments through intermediaries
- discussions about benefits for officials or decision-makers
- requests for irregular or unsupported invoices
Why it matters
Bribery rarely appears as an explicit transaction — it's disguised as representation expenses, intermediary commissions, or donations to foundations linked to the official. The FCPA and UK Bribery Act have extraterritorial reach: a Chilean or Brazilian company with US or UK operations or investors can be exposed even if the payment happens entirely in its home country. And unlike other conduct types, criminal liability here falls directly on the individuals involved, not just the company.
Relevant regulatory framework
- Chile — Law 20.393 (corporate criminal liability)
- Brazil — Lei 12.846/2013 (Anti-Corruption Law)
- Argentina — Law 27.401
- USA — FCPA
- UK — Bribery Act 2010
- OECD — Anti-Bribery Convention
Recommended action
- 1Verify the documentary backing of any payment to a local intermediary or consultant before processing it.
- 2Escalate to legal any payment request outside the standard approval process.
- 3Check whether the payment directly or indirectly involves a public official or their close circle.
- 4Document the legitimate business purpose of any representation expense or donation.
Is your organization exposed?
vario identifies these signals automatically in corporate emails, Slack, Teams and WhatsApp.
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