Jurisdiction(s):
United Kingdom

Key definition

Bribery definition

What does Bribery mean? Bribery describes the offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage to induce or reward the improper performance of a function or to influence a person in a position of trust. In England & Wales, Scotland and Northern Ireland, bribery is principally governed by the Bribery Act 2010, which consolidated and reformed the law. It creates offences of active and passive bribery (sections 1–2), bribery of a foreign public official (section 6), and the corporate offence of failure to prevent bribery by associated persons (section 7), with a statutory defence of having adequate procedures....

Third-party agents and intermediaries: financial crime red flags (fatal and non-fatal) and due diligence checklist

Published by a LexisNexis Practice Compliance expert

Precedents

We conduct our business [ es ] with integrity. We must all work together to ensure our business [ es ] [ remains OR remain ] free from financial crime. The points below outline factors we believe heighten the likelihood of improper conduct by an agent or intermediary. Non-fatal red flags can be addressed through further due diligence. Fatal red flags are so serious and present such a high risk that they cannot be resolved and result in the immediate ending of existing business relationships or the engagement process. For more information, see our [ Agents and intermediaries policy and Due diligence flowchart ].

FATAL red flags NON-FATAL red flags

Any past convictions for financial crime offences, eg bribery, facilitation of tax evasion, or fraud.
The agent/intermediary has at any time asked another organisation to produce sham invoices or other forms of false documentation.
The agent/intermediary declines to agree to confirm compliance with applicable international laws and [ insert organisation’s name ]’s policies...

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Web page updated on 22/05/2026

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