Recognize non-cash benefits that can qualify as improper value in bribery risk analysis.
Cash is only one delivery mechanism for improper influence. Value Can Be Personal A benefit can be valuable because it helps the official, a relative, a favored charity, a political ally, or a business they secretly control. The anti-bribery question follows the benefit to the person who gains from it. Timing Changes The Risk A modest item far from a decision may be routine. The same item during a tender, audit, inspection, license renewal, or payment dispute may look like an attempt to influence. Timing is often the evidence that turns a courtesy into a problem. Transparency Is A Control…
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