If your business has no alternative but to make facilitation payments the SFO want to know about it, understand it, learn from you what your strategy is to curb the problem and suggest methods to do so.
If a business does not do this the risk is that the SFO will conclude that it falls into the group of companies they are very keen to prosecute, namely those who the SFO believe have no intention of stopping paying facilitation payments and who use them to disadvantage those who are taking active steps to curb them and stamp them out.
‘Enforcement 40’ for 2020
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