W. Michael Kramer, JD, CFE
Specialist in Corruption and Fraud Investigations

Corruption and Fraud in International Projects
THE PRIMARY RED FLAGS
OF CORRUPTION AND FRAUD
The Primary Red Flags of Bribes and Kickbacks
- The appearance of local "agents" that provide ill-defined,
generic, or unneeded services. Many of the warning signs are rather obvious
and include:
- The agent operates in a country with
a reputation for corruption · Government or project officials recommend
or insist on a particular agent
- The agent's fee is too large for the services to be provided
- The agent provides little or
no useful services or work product
- The agent's compensation is calculated as a percentage of the
contract value rather than on a time or services basis
- The agent's contract is boilerplate and
only vaguely describes the services to be provided
- The agent has no permanent business premises or staff
- The agent requests payment to an account in a secrecy jurisdiction
- Unexplained or unusual delays in the procurement process (as kickback
amounts are negotiated or project officials try to defeat the controls)
- Unjustified
or repeat sole source awards
- (Repeated) selection of high priced
or unqualified contractors
- A project official insists on the use
of certain local subcontractors or suppliers
- Project employee lives
beyond his or her means
- Close socialization; gifts and gratuities to
project
officials
Primary Red Flags of Bid Rigging
Red flags of bid rigging as the result of collusion between contractors and project officials include:
- Reputation or history of corruption in the country or business line
- Bid specifications are too narrow or too vague
- Unreasonable pre-qualification
requirements
- Unreasonably short time to submit bids
- Selection of unqualified
(local) contractors
- Selection of other than the low bidder
- Selection
of low bidder followed by a change order increasing price or scope;
- Extending an expired
contract rather than re-bidding
- Questionable disqualification of
winning bidder and re-bidding
Red Flags of bid rigging as the result of the existence of local bid-rigging cartels or collusion between bidders include:
- Persistent high bid prices
- Few bidders, same bidders
- Rotation of winning
bidders; losing bidders become subcontractors
- Use of bid protests or
other means to exclude new bidders
- Bid prices drop when new bidder enters
- Apparent connections between bidders affiliated companies, same fax
numbers on bidding documents, etc
Primary Red Flags of Fraud
- Poor quality works, frequent repairs, early replacement; e.g., roads
scheduled to last ten years fall apart after two
- Repeated failed tests or inspections
- Delays or refusals to allow tests or
inspections, or contractor or project officials conduct tests or
choose sites
- Complaints from users or beneficiaries
- Services provided by unknown
or unqualified vendors
- Corruption of inspectors and site supervisors
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