At a recent training session, I was talking about the Bribery Act 2010. (Normally I try to stick quite closely to money laundering, on the basis that all crimes lead to laundering anyway, and if I start diverging into fraud, say, or bribery, shouldn’t I also go into detail about drug trafficking and tax evasion, and that way madness lies. But the Bribery Act has scared MLROs so much that I have decided to make an exception for it.) And during the break, a delegate told me an interesting story.
She said that on a recent trip to an Asian country well-known for the corruptness of its public servants, she was detained at the airport. The immigration officer had supposedly detected damage on her passport and was querying its validity. Struggling to see the problem, my delegate finally realised that she was being asked for a facilitation payment – a bribe – to gain access to the country. And then, being a well-brought-up girl, and moreover working in compliance, she found herself in a dilemma of morals and etiquette. The moral bit was easy: stranded in a foreign country, she quickly decided that she would indeed pay. But how to broach the subject? Debrett’s, I fear, is silent on the subject. One cannot simply blurt out, “How much do you want, you larcenous individual?”. Eventually, through various half-sentences, she conveyed that she would indeed be willing to make a donation to his favourite charity.
With an upper limit in her mind of £300, she offered £100. The immigration officer looked shocked. “Oh no, madam – that is far too much!” It appears that there is an acceptable level of criminality – honour among extortionists and all that. £40 changed hands, and my delegate continued on her way – with a more practical understanding of the mechanisms of bribery than most of us will ever have.