Have communications or financial transactions around the transaction been conducted, or are they planned to be conducted, in a manner that is secretive or not transparent?

Examples of secretive or non-transparent methods include:

• Using personal or alias non-work email or text messaging accounts or  off-book communication systems
• Using only handwritten notes or meeting only in person
• Using side agreements
• Using pseudonyms or code names
• Using off-the-book financial accounts or approval systems
• Recording transactions in a spreadsheet rather than through the company's financial system
• Destroying invoices or communications soon after payment
• Excluding information in payment communications that identifies the recipient
• Being told to “be careful” or to mask the true circumstances of a transaction (e.g., employees instructed not to speak to other company employees about the matter or told, “the fewer words the better”)
• Being told to structure transactions or payments to avoid countries that are more likely to enforce anti-corruption laws (e.g., being told to engage entities outside of those countries or use banks not located in those countries)

Have communications around the transaction used any suspicious or vague code words that that do not sufficiently or accurately describe the nature of the expense or suggest that the transaction may not be appropriate?

Examples of suspicious or vague code words include:

• Miscellaneous,” “extra,” “additional,” “other,” “out of pocket,” “special handling or processing,” "unofficial," or “unanticipated” expenses
• “Extraordinary,” “urgent,” or “emergency” expenses
• “Intervention,” “facilitation,” “formalities,” or “verification”
• Social,” “support,” “commitment,” or “toll” expenses for “key players,” “our people,” “our team,” “supporters,” “good guys,” “conduits,” or “friends”
• "Third world tax,” or “payoff”
• “Flower,” “landscaping” or “sunshine” expenses
• “Black cash,” “black money,” “chocolates,” or “kiss money”

Will the meal or beverages be provided or reimbursed in any of the following ways:

The use of off-the-books accounts, third-party accounts, personal accounts of employees, “cash desks,” “cash safes," or reimbursing employees outside of the ordinary reimbursement process for such expenses suggest a lack of transparency and increases the risk that the expense is inappropriate.

Any expense for meals or beverages should also be supported by invoices or receipts that accurately describe the meals or beverages and its cost.  When using a travel agency to arrange meals or beverages, documentation from the underlying hospitality venues should be provided or available upon request.

Payments should generally not be made directly to government officials or employees of current or potential customers, but instead to the government or customer employer or to service providers the company uses, such as travel or hospitality providers (e.g., airlines or hotels) in the case of travel or hospitality.  If a government official or employee of a current or potential customer requires direct payment, the reimbursement should be supported by detailed receipts, and should not be made in cash.  In addition, if a government official or employee of a current or potential customer designates a travel agency or other third party to whom payment must be made, the risk of corruption increases because the third party may be connected to the individual, or may otherwise be colluding with the individual, and the individual may be receiving an improper personal benefit.

Providing payments or benefits in a manner that is different than the company's ordinary financial or approval processes or in any other way that differs from how similar expenses would be paid or reimbursed suggests an intention to disguise the payment or benefit, and increases the risk that the payment or benefit is improper.

Information text presented to the requestor:

Examples of unusual reimbursement arrangements include:

• Booking the expense to incorrect or vague general ledger accounts or  to multiple account unnecessarily
• Booking the expense outside of the company’s financial system
• Structuring payments into multiple payments or through multiple company bank accounts
• Making payments to multiple recipients or recipient bank accounts, or unrelated third parties
• Paying the expense through inter-company accounts meant only for payments between company entities
• Using manual payment processes reserved for emergency payments
• Using discretionary accounts not typically used for paying for such expense
• Paying the expense without the approval of individuals with the required approval authority
• Structuring the payment to avoid using a bank based in a country that aggressively enforces anti-corruption laws
• Making the payment before the signing of the related agreement or immediately upon the awarding of sales or favorable government or customer action