SFO & Five Eyes Publish New Guidance on Indicators of Foreign Bribery

Key Takeaways

• Joint Enforcement Signal: The UK Serious Fraud Office and Five Eyes partners have published their first agreed set of foreign bribery indicators, reflecting shared investigative experience across jurisdictions.
• Early Risk Detection Tool: The guidance is designed to help businesses, compliance teams, and professionals spot patterns that may indicate bribery risk before misconduct escalates.
• Context Matters: Individual indicators do not imply criminal activity on their own; risk emerges when multiple factors appear together or conflict with a company’s broader risk profile.
• Overlap With Financial Crime: Several indicators mirror red flags seen in money laundering cases, reinforcing the need for integrated financial crime and bribery risk assessments.
• Encouragement to Report: Authorities are urging organizations and individuals to report suspected foreign bribery to the appropriate national enforcement bodies.

Deep Dive

Foreign bribery cases rarely begin with a single, obvious act. They tend to surface through patterns, unusual secrecy, opaque ownership structures, and contracts that don’t quite add up. That reality is at the heart of new guidance released this week by the Serious Fraud Office and its Five Eyes law-enforcement partners.

The guidance marks the first time the International Foreign Bribery Taskforce (IFBT) has jointly issued a consolidated set of Indicators of Foreign Bribery, distilling decades of investigative experience into practical warning signs designed for businesses, compliance teams, and professionals working in higher-risk environments.

The taskforce brings together enforcement agencies from across the Five Eyes alliance, including the National Crime Agency, the Australian Federal Police, the Royal Canadian Mounted Police, the New Zealand Police, the New Zealand Serious Fraud Office, and the Federal Bureau of Investigation.

Rather than introducing new legal obligations, the guidance reflects what investigators say they see repeatedly once cases begin to unravel. It is aimed at helping organizations recognize when activity may be drifting into higher-risk territory, often long before any allegation of bribery formally emerges.

The indicators themselves span financial, structural, and behavioral red flags. These include ownership of high-value property portfolios that appear disproportionate to known income, the creation of charities sharing names with commercial entities, and demands for unusual secrecy around contracts or transactions. Other examples include complex layers of corporate ownership that obscure who ultimately controls a business, or contracts awarded to parties that lack the apparent capability to perform the work.

Crucially, the taskforce stresses that none of these indicators should be viewed in isolation. On their own, many may have benign explanations. The risk, investigators note, lies in how they cluster together and how they sit within the broader context of a company’s operations, counterparties, and geographic exposure.

The guidance also acknowledges overlap with other forms of financial crime. Many of the indicators are familiar from money laundering cases, reinforcing the need for organisations to assess them as part of an integrated risk profile rather than treating foreign bribery as a standalone issue.

The IFBT is encouraging anyone who encounters activity that may point to foreign bribery to report it to the appropriate authority in their jurisdiction. In the UK, reports can be made to the SFO or the National Crime Agency.

Balinder Matharu, Head of Intelligence Analysis at the Serious Fraud Office, said the publication reflects the increasingly cross-border nature of bribery investigations.

“Foreign bribery is a complex problem that demands a global response,” Matharu said. “This guidance brings together decades of intelligence and investigative experience from the world’s leading law enforcement agencies. Prevention is always better than prosecution, and this collaborative approach demonstrates our commitment to working with our law enforcement partners to tackle economic crime.”

The joint release is a part of a broader shift in enforcement strategy, placing greater emphasis on early detection and prevention and on giving businesses clearer signals of what investigators look for when foreign bribery cases begin to take shape.

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