Five Eyes “Indicators of Foreign Bribery” – a new baseline for bribery risk

There is, however, nothing especially revelatory in the substance. Many of the indicators are the basic building blocks of modern anti-bribery compliance: the use of third-party agents and consultants; opaque or unnecessarily complex ownership structures; the involvement of shell companies; unusually high commissions; and public sector touchpoints, including dealings with politically exposed persons.

Most organisations with mature bribery programmes will already recognise these red flags, and many will have controls expressly designed around them.

That said, the publication still matters. It sets a useful baseline – a shared, international statement of what participating agencies say they look for when triaging foreign bribery risks. It also sits within a wider push toward operational cooperation, at a time when enforcement approach and priorities may not be fully aligned across jurisdictions.

For global organisations, the practical question is less “what's new?” and more “does our programme still line up with the red flags agencies are now putting in one place and encouraging the market to report?”

Context and background

A familiar set of indicators, now gathered under a single banner

The indicators cover a wide range of conduct and structuring commonly associated with bribery risk: intermediaries with unclear roles; payment terms that do not reflect legitimate services; “special purpose” entities used to receive fees; unusual secrecy around documentation; or transactions that appear to lack commercial logic.

This is the same territory covered by multiple public typology documents already in circulation – in many cases with more detail and richer explanation.

A particularly strong comparator is Transparency International's “How to Bribe” typology guide (first published in 2014), which sets out common bribery methods and the mechanics by which value is transferred in practice.

In that sense, the IFBT guidance can look a little too simplistic: it states the indicators, but does not linger on the “how” or “why”, and it does not always translate a red flag into what an organisation should do next by way of controls or investigation steps.

Even so, the IFBT document has a distinct function. It provides a shared minimum standard – a consolidated set of triggers that multiple agencies are willing to endorse publicly, and which they appear to encourage the market to use as a prompt for escalation.

The guidance also sets out the legislative backdrop across participating jurisdictions. This is unlikely to transform programmes that are already designed around core anti-bribery principles.

It does, however, reinforce an important reality for multinational businesses: foreign bribery risk is rarely confined to one statute, one regulator, or one enforcement body. Parallel jurisdictional hooks can arise quickly, particularly where payments, intermediaries, financial institutions, or corporate vehicles sit across borders.

Analysis – why publish something like this now?

Establishing a common language for suspicion

The most meaningful feature of the IFBT indicators is not their novelty but their standardisation. A shared list of warning signs makes it easier for agencies to align on early-stage judgement calls: what looks suspicious, what warrants follow-up, and what should be escalated or shared.

For businesses, that has a simple implication. If the same patterns are being flagged across multiple jurisdictions, those patterns are more likely to attract interest when they appear in internal audit findings, whistleblowing reports, due diligence files, or transaction monitoring outputs. The indicators function as a public signal of what is likely to be treated as “worth a look”.

A baseline tool – and a prompt for refresh

Because the list is largely comprised of familiar red flags, it should not be transformative for organisations with a mature bribery framework: policies, training, third-party diligence, gifts and hospitality controls, and a functioning speak-up route. In many cases, compliance teams will be able to demonstrate that the indicators are already captured in risk assessments and control testing.

Where the guidance can be useful is as a trigger for a structured refresh. A common issue is not the absence of controls, but drift: policies that have not been revisited, diligence questionnaires that no longer reflect current typologies, or approvals processes that have become routine and under-challenged. Running an explicit “IFBT indicators” cross-check can be an efficient way to validate whether the programme still reflects the red flags agencies are actively encouraging the market to report.

The signal of international cooperation – and why the U.S. angle matters

The IFBT indicators sit within a broader trend: international cooperation on foreign bribery is increasing, even where national enforcement priorities are not always aligned.

First, cooperation is becoming more routine and more operational. Agencies are sharing typologies and intelligence earlier, which makes it easier for concerns identified in one jurisdiction to be pursued in another.

Second, recent U.S. policy signals reinforce the importance of that cooperation. In June 2025, the DOJ's revised FCPA enforcement guidelines directed prosecutors to consider, before opening a new investigation, whether an appropriate foreign authority is “willing and able” to investigate and prosecute the same alleged misconduct. That approach creates more space for non‑U.S. agencies to take the lead where U.S. interests are not directly engaged.

Third, the UK is signalling that it is prepared to step into that space. Nick Ephgrave, the Director of the SFO, has described the SFO's relationship with the DOJ as “strong” and “fruitful”, and the agencies have reiterated a shared focus on cooperation, voluntary self‑disclosure and faster cross‑border resolutions. The SFO has also sought to broaden its international reach beyond the U.S. relationship – including joint working with European partners and participation in the International Anti‑Corruption Coordination Centre (IACCC) – to support intelligence gathering and evidence development in overseas corruption matters.

For multinationals, this is where a basic set of shared indicators is significant. As cooperation increases and the U.S. signals greater willingness to let foreign authorities lead, businesses should assume that potential issues may be picked up – and progressed – across multiple jurisdictions in parallel. The practical response is to keep a clear view of jurisdictional exposure, structure internal investigations for cross-border use (including evidence handling and privilege), and take self-reporting decisions as a coordinated package – avoiding any perception of “forum shopping” by engaging one authority while delaying engagement with another.

Conclusion

The IFBT's “Indicators of Foreign Bribery” do not break new ground. They are, in large part, a consolidation of well-understood risk markers that most organisations are already aware of.

Their practical value is that they set a common baseline and provide a simple external benchmark for refreshing and, where necessary, tightening controls. The wider significance lies in what the document represents: a continued push toward shared typologies and cooperation across key enforcement partners, at a time when enforcement priorities are not uniform.

Ultimately, the IFBT's indicators serve as a timely reminder for organisations to refresh their controls and remain vigilant amid growing global cooperation in anti-bribery enforcement. At the same time, corporates should not overlook domestic bribery risk. Recent UK cases – including the conviction of a former Welsh MEP under the Bribery Act and the imprisonment of four individuals for demolition industry corruption worth over £600,000 – underline that enforcement priorities are not solely focused on foreign bribery. Compliance frameworks must address domestic risk with equal rigour.

Authored by Reuben Vandercruyssen, Olga Tocewicz, and Alex Cumming.