Facing Up to Demands for Small Bribes: Legal Requirements and Operational Challenges in Weak Government Zones

摘要

Until recently, international anti-corruption initiatives focused almost exclusively on ‘grand bribes’ to secure contracts or obtain licenses. Now small bribes or ‘facilitation payments’ connected with day-to-day operational matters such as customs clearances, environmental inspections and security are rising up the international legal and corporate agendas. The increased focus on small bribes reflects wider international enforcement trends, including in the US. However, the greatest single driver has been the UK Bribery Act, which does not distinguish between large and small payments.