ICG AC (CGCAT) key terms

Offering, promising, giving, requesting or accepting an undue advantage to influence the recipient's conduct, whether in the public or private sector, directly or through an intermediary.

Any benefit, financial or otherwise, to which the recipient is not lawfully entitled, including cash, gifts, contracts, jobs or favourable treatment. The concept does not require the benefit to be paid.

A secret payment or benefit returned to a person who controls or influences a transaction, typically a portion of the contract value, in exchange for awarding or steering business.

Bribery between private parties, such as an employee of one company paying an employee of another or of a supplier to obtain business advantage, without any public official being involved.

A person holding a legislative, administrative or judicial office, exercising a public function, or working for a state-owned or state-controlled entity. The exact scope varies by statute and must be checked.

A public official of another country or of a public international organisation. The FCPA and UK Bribery Act both reach bribery of such persons, regardless of where the conduct occurs.

A term used in some statutes, notably Singapore's Prevention of Corruption Act, for any money, gift, loan, favour or advantage. It is broader than cash and includes non-financial benefits.

The US Foreign Corrupt Practices Act, which criminalises bribery of foreign officials by issuers and domestic concerns and requires accurate books and records and internal accounting controls.

UK legislation creating offences of bribing, being bribed, bribing a foreign public official and failing to prevent bribery by an associated person, with no facilitation payment exception.

The OECD Anti-Bribery Convention, which requires signatories to criminalise bribery of foreign public officials in international business transactions and to cooperate in enforcement.

The UN Convention against Corruption, a global treaty covering prevention, criminalisation, asset recovery and international cooperation. It sets minimum standards that states implement in domestic law.

A UK Bribery Act offence where a commercial organisation is liable for bribery by a person associated with it, unless it can show adequate procedures were in place.

The UK statutory defence to the failure-to-prevent offence, comprising proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.

A person performing services for or on behalf of a commercial organisation, including employees, agents, subsidiaries and intermediaries. The label is functional, not contractual.

An external party such as an agent, consultant, distributor, joint-venture partner or subcontractor that acts for the company and may interact with officials on its behalf.

Risk-based inquiry into a counterparty's ownership, reputation, government links and ability to perform, done before engagement and refreshed periodically to decide whether to proceed and on what terms.

Deeper scrutiny applied to higher-risk counterparties, such as politically exposed persons or state-linked agents, including source-of-funds checks, site visits and independent background verification.

The identity of the natural persons who ultimately own or control a legal entity, even where shares are held through nominees or layered companies. It is central to third-party risk checks.

A person entrusted with prominent public functions, and their family and close associates, who presents higher corruption risk and requires enhanced scrutiny before any engagement.

A structured evaluation of the likelihood and impact of corruption across countries, sectors, transactions and business partners, used to allocate controls proportionately and to update them over time.

The combined policies, procedures, controls, training, monitoring and governance a company uses to prevent, detect and respond to bribery, scaled to its identified risks.

Visible, consistent commitment from senior leadership that bribery is not tolerated, reflected in decisions, incentives and messaging rather than policy statements alone.

The person responsible for designing, running and monitoring the anti-corruption programme, with sufficient authority, independence and resources to challenge business decisions.

A small payment to a low-level official to speed up a routine action the payer is already entitled to, such as issuing a permit. Lawful in some jurisdictions, prohibited under the UK Bribery Act and many corporate policies.

An informal synonym for a facilitation payment, emphasising a small sum used to lubricate routine administrative action. The label does not make the payment lawful under all regimes.

A voluntary transfer of value given without expectation of return. In compliance terms, gifts must be modest, transparent, recorded and within policy limits, especially when offered to officials.

Entertainment, meals, travel or accommodation provided to a counterparty. Legitimate when reasonable, business-related and transparent, but it becomes a risk when lavish, undisclosed or timed to influence a decision.

A situation where a person's private interests, such as a family link to a supplier, could improperly influence their professional judgement. It must be disclosed and managed, not merely avoided.

A violation of accounting provisions requiring transactions to be recorded accurately and in reasonable detail, so that falsified or off-book entries can be prosecuted even without proof of bribery.

Systems designed to ensure transactions are authorised, recorded and reported as management intends, and that assets are safeguarded. Weak controls are a common enforcement finding.

A bank account, ledger or fund kept outside the company's official records, often used to hold slush funds for improper payments. Its existence is itself a serious red flag.

A warning indicator that corruption risk may be present, such as an unusual success fee, a shell company, an official with a family link to a vendor, or a refusal to certify compliance.

An entity with no real operations or staff, often incorporated in a secrecy jurisdiction to hold funds or contracts. It can be legitimate but frequently masks beneficial ownership in bribery schemes.

A commission paid on a percentage of contract value. It is a red flag when unusually high, undisclosed, paid offshore or disproportionate to the agent's real work.

A structured, privileged where possible inquiry into suspected misconduct, covering scoping, evidence preservation, interviews and reporting, conducted fairly and documented contemporaneously.

Reporting of suspected wrongdoing by an employee or other insider through protected channels. Effective programmes offer confidentiality, anonymity where possible and protection from retaliation.

An environment where staff feel safe to raise concerns without fear of retaliation, supported by accessible reporting channels and visible follow-through by management.

Corrective action taken after a compliance failure, including discipline, control fixes, training, third-party termination and monitoring, to prevent recurrence and demonstrate good faith.

Voluntarily disclosing suspected misconduct to enforcement authorities before they discover it, often rewarded with reduced penalties or declinations when paired with cooperation and remediation.

Reduced penalty or leniency granted to organisations that cooperate genuinely with investigators, for example by providing evidence, making staff available and remediating promptly.

An agreement under which prosecution is suspended in exchange for conditions such as a financial penalty, cooperation and compliance reform, used in the UK and US for corporate cases.

An arrangement where an independent monitor oversees a company's compliance reforms for a set period, typically imposed as a condition of a settlement with authorities.

A formal channel through which states request and provide evidence and other help for criminal investigations, used where cross-border corruption cases require foreign-held evidence.