The three primary ways to prove corrupt payments and fraudulent transfers are:
- Out from the suspected point of payment, i.e., from an examination of the books, records and accounts of the entity suspected of paying bribes or making fraudulent transfers;
- Back from the suspected point of receipt, i.e., from the accounts and financial records of the person suspected of receiving the illicit funds, or by
- Obtaining the cooperation of an inside witness, such as a co-conspirator, middleman or the bribe payer. This approach may be necessary to find well-hidden or laundered payments; see Step Eight, below.
The three approaches are illustrated in the chart:
A covert or “sting” operation might be effective if the scheme is on-going and the subjects are not aware of the investigation. This approach requires considerable experience, preparation and risk, and is not discussed here.
Click on the links below for more detailed information:
How to Prove Illicit Payments from the Point of Payment
How to Prove Illicit Payments from the Point of Receipt