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. 

Where the corrupt participant is an individual, it is important to identify whether they are acting for their personal benefit, or are acting on behalf of their employers.  In the latter case, both the individuals and their employers could be criminally liable.

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 Finance Director and other RA personnel may have no knowledge or involvement
• both BuildWell and the site engineer may be involved in the fraud; the Finance Director and other RA personnel may have no knowledge or involvement
• all of BuildWell, the site engineer, the Finance Director 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).