Connect the benefit to the funds
Corruption can create illicit benefits, including money diverted from public resources or received through bribery. Laundering can then conceal the proceeds and their beneficiary.
AUSTRAC’s historical analysis describes the use of companies, intermediaries and international transfers to hide these proceeds. It is evidence of methods, not current offence wording.
Examine the stated commercial purpose
A payment may be described as a fee for services. A useful review compares that description with the work, agreement, payer and recipient.
The reviewer records any supported connection between the recipient and the decision or contract concerned. An unsupported association is not a finding of corruption.
Source: AUSTRAC: Key points; Background.
- Work
What service is said to have been provided?
- Payment
Who paid and who received the funds?
- Connection
What evidence links the recipient to the decision?
Test the stated fee
Suggested evidence questions. A fee or public role alone is not proof of corruption.
Connected concepts. Lines do not show ownership or a reporting hierarchy.
Invented example: a fee with no supported service
In an invented review, a payment is described as an advisory fee. The supplied agreement does not describe the work covered by the payment.
The reviewer asks what work the fee covers. It compares the answer with the available agreement and payment information.
The missing description may have a legitimate explanation. A conflicting account may need escalation. The reviewer records evidence and uncertainty separately.
Source: AUSTRAC: Key points; Background.
PEP status is a separate question
A politically exposed person is not necessarily corrupt. The classification concerns a public role and its associated risk.
The PEP article describes classification and required CDD treatment. A corruption concern needs its own evidence and a separate reporting assessment.
Source: AUSTRAC: Politically exposed persons.