Which participants are responsible

It is important in an investigation to be alert to the possibility that more than one project participant could be involved in the corruption. 

For example, if BuildWell submits a fraudulent payment application to RA deliberately claiming payment for a greater quantity of work than actually done, or payment for quality greater than actually supplied:

• only BuildWell may be involved in the fraud; the site engineer and other RA personnel may have no knowledge or involvement
• both BuildWell and the site engineer may be involved in the fraud; other RA personnel may have no knowledge or involvement
• all of BuildWell, the site engineer, and other RA personnel may be involved in the fraud
• in addition, one or more sub-contractors and suppliers may be involved (e.g. providing, at the request of BuildWell, false documentation).

A corrupt act is always undertaken by a person.  It is important to identify whether this person is acting for their personal benefit, or is acting on behalf of the organisation they are employed by.  In the latter case, depending on the relevant country’s laws, both the person and their employer could be criminally liable.