Bribery, corruption and money laundering: how bribes are laundered and what banks check

Bribery and money laundering are often read as one offense. They are two crimes fed by one payment: the bribe, then the laundering that makes each share look clean. The Foreign Corrupt Practices Act (FCPA) of 1977 punishes a payer within its reach that corruptly offers a foreign official anything of value to win or keep business; the official who took the money sat outside it.

Since 30 July 2024 the US Code has carried the Foreign Extortion Prevention Act (FEPA) as section 1352 of Title 18: a foreign official who corruptly demands or accepts a bribe from a US issuer or domestic concern, or from anyone while in the United States, commits a crime of its own, with up to 15 years in prison.

Is bribery money laundering?

Bribery on its own is a separate crime. It produces criminal proceeds on both sides of the payment, and moving or hiding those proceeds is laundering.

On the official's side, the US laundering statute, section 1956 of Title 18, lists bribery of a public official, as an offense against a foreign nation, among its specified unlawful activities when the financial transaction occurs in whole or in part in the United States. On the payer's side, it lists "any felony violation of the Foreign Corrupt Practices Act". Moving either pot can bring a money laundering charge.

UK law gets there through section 340 of the Proceeds of Crime Act 2002, its interpretation section. Conduct abroad counts as criminal conduct when it would be an offense in any part of the UK had it happened there. Property is criminal property when it is a person's benefit from that conduct, obtained "as a result of or in connection with" it, provided the alleged offender knows or suspects that it is such a benefit. The official's bribe and the payer's contract revenue can both fit.

In the EU, Article 10 of Directive (EU) 2026/1021 requires member states to make it a crime to conceal or disguise property intentionally, knowing it derives from bribery or another offense the article lists. Recital 22 says this is without prejudice to the 2018 directive on money laundering offenses.

Who launders the bribe: the payer or the official?

Both can. The official needs the bribe to look like income; the payer needs it to look like an expense and the contract revenue to look earned. In the 2026 Corsa Coal trial, commissions paid to an intermediary funded the bribes and came partly back as kickbacks to the executive who arranged them, Charles Hunter Hobson, according to the Justice Department's release on the verdict.

Bribery, corruption and money laundering: what is the difference?

Bribery is one corrupt act. Section 1 of the Bribery Act 2010 makes it an offense to offer, promise or give an advantage intending to induce or reward the improper performance of a relevant function. Article 3 of the EU directive covers both directions: an undue advantage promised, offered or given to a public official, and the official's request for or receipt of one, directly or through an intermediary, so that the official acts or refrains from acting in office.

Corruption is the wider family. It takes in bribery, the misappropriation of public funds and other abuses of office, and money laundering is what turns the proceeds of any of them into money that looks lawful. When the theft runs through the state itself, the pattern has its own name: kleptocracy.

Picture an illustrative customs officer paid $5,000 to clear a container. The payment is bribery, the officer's abuse of office is corruption, and depositing the cash as takings from a side business is laundering.

How are bribes paid and laundered?

On 19 February 2026 the Justice Department announced that a federal jury had convicted a former Corsa Coal international sales vice president over a scheme to bribe Egyptian government officials in connection with nearly $140 million in coal supply contracts. Between 2016 and 2020 the bribes bought coal sales to a chemical maker then owned and controlled by the Egyptian state. They left as purported sales commissions to an intermediary in Egypt, who received more than $4.8 million, and were laundered through bank accounts in the United States and the United Arab Emirates. The intermediary also paid the executive over $200,000 in kickbacks. The Justice Department had closed its case against the company in March 2023 with a declination and the disgorgement of profits.

A second verdict, on 6 August 2026, came from inside banking. A former executive director in Goldman Sachs' investment banking division, Asante Kwako Berko, was convicted of FCPA and money laundering conspiracy charges over a scheme to pay more than $1 million in bribes to Ghanaian government officials in connection with a power plant. The bribes were hidden through shell companies, sham invoices, nominee account holders and cash withdrawals, and moved through US and foreign accounts, several in the banker's own name. Goldman pulled out over corruption concerns.

Both cases follow the routes in FinCEN's 2022 corruption advisory: bribes paid through third parties or through legal entities controlled by family members and close associates, then laundered through shell companies, offshore financial centers or professional service providers.

For a bank, each of those routes arrives as a customer or a counterparty: the intermediary's company, the official's relative, the shell that sends the invoice. complead, formerly Sanction Scanner, screens such parties through its client screening and ongoing monitoring product. Behind every check stand 3,500+ sanctions, PEP and watchlists from 220+ jurisdictions, refreshed every 15 minutes, at onboarding and again later in the relationship.

Which laws connect bribery and money laundering?

The maximums are statute maximums; sentences in real cases differ.

Table 1. What makes a bribe a money laundering matter (as of November 2026)

FEPA is the newest row. It reaches a foreign official who corruptly demands or accepts anything of value through the mails or interstate commerce, from a US issuer or domestic concern or from anyone while in the United States, in return for official action, influence or an improper advantage in winning or keeping business. Its foreign official includes any senior foreign political figure as FinCEN's rules define one, the population a PEP screen looks for. The offense carries extraterritorial jurisdiction.

EU member states must bring national law into line with the directive by 1 June 2028, and by 1 June 2029 for Articles 20(5) and 21. The directive's Article 9 asks for an offense for an official who acquires, holds or uses property knowing, at the time of receipt, that it derives from another official's corruption offense. Denmark took no part in adopting it and is not bound by it.

What are the red flags of bribery proceeds?

FinCEN's advisory supplies most of these indicators and the 2026 cases add the rest. None proves a bribe alone.

1. Contracts that keep going to the same owners. Long running government contracts awarded through an opaque process to the same company, or to companies with similar owners. Why: the award is where a bribe pays off.
2. Official business through personal accounts. Embassy or foreign government business run through an individual's account. Why: state money leaves the state's records.
3. Assets beyond the declared wealth. Real estate or luxury goods an official's reported source of wealth cannot explain. Why: this is where a bribe gets spent.
4. Money moving to countries with no tie. An official's funds going to or coming from countries the official has no apparent connection to. Why: nothing on file explains the route the money takes.
5. Agent commissions out of line with the work. Corsa's intermediary took more than $4.8 million in commissions, and the SFO's agreement with Ultra Electronics covered public sector contracts sought through agents. Why: a commission, like an invoice priced well above market, can carry a bribe.
6. Payments that do not match the paperwork. Amounts that differ from the contract or invoice totals, or payments routed through shells and nominee holders, as in the Ghana scheme. Why: the gap can be the bribe.
7. Cash withdrawals from commission or contract money. The Ghana bribes were laundered partly through cash withdrawals. Why: cash cuts the trail between the payer's account and the official.
8. A deal team that keeps compliance out. The Goldman banker lied to the compliance team vetting the deal and discussed the bribes on a personal email account. Why: hiding a deal from the firm's own reviewers is a signal.

What should a compliance team do about bribery risk?

FATF Recommendation 12 expects financial institutions to identify foreign politically exposed persons, take reasonable measures to establish their source of wealth and source of funds, and monitor the relationship more closely. UNCAC Article 52 asks for enhanced scrutiny of their accounts and of their family members and close associates. PEP screening is the first control.

Because there is no global PEP register, complead assembled its PEP database one source at a time over six years. It covers four PEP categories. They run from heads of state down to local officials, and each record carries the person's relatives and close associates.

For a foreign PEP, a confirmed match opens enhanced due diligence. Test the account of how the source of wealth was built against declared income, asset disclosures and public registers. An adverse media check run with bribery terms, translated for each country the person works in, can surface reporting no list carries.

When the red flags survive review, file a suspicious activity report and, as FinCEN's advisory asks, put the key term "CORRUPTION FIN-2022-A001" in SAR field 2 and in the narrative, with field 38(m) selected.

Executive Order 14209 of 10 February 2025 told the Attorney General to stop opening new FCPA investigations or enforcement actions for 180 days, barring individual exceptions. It does not mention SAR filing, and FinCEN still lists the advisory on its advisories page as of November 2026.

What does bribery risk look like inside a bank?

Staff are part of the risk. Article 15 of the EU directive lets member states treat a corruption offense as aggravated when the offender is an obliged entity, or one of its employees acting in the course of professional activities.

Anti bribery and corruption (ABC) programs ask whether people acting for the firm pay bribes: under section 7 of the Bribery Act a company formed or trading in the UK commits an offense when someone associated with it pays a bribe to obtain or retain its business, and it has a defense if it proves adequate procedures were in place. AML asks whether money passing through the firm came from bribery. The Ministry of Justice guidance notes that, unlike US foreign bribery law, the Bribery Act gives facilitation payments no exemption.

Is hush money illegal, and when is it a money laundering problem?

In January 2025 the SEC settled charges with WWE's former CEO for signing two settlement agreements, in 2019 and 2022, without telling the board, the accountants or the auditor; WWE restated its accounts. Without admitting or denying the findings, the former CEO agreed to pay a $400,000 civil penalty.

Hush money buys silence. Whether it is illegal turns on what the silence covers and how the payment is booked. Section 1512(b) of Title 18 covers knowingly and corruptly persuading a person with intent to influence, delay or prevent testimony in an official proceeding. Section 201(b)(3) covers corruptly giving anything of value to influence a witness's testimony under oath at a trial, hearing or other proceeding before a court, Congress or a federal agency.

For a listed company, section 78m(b) of Title 15 requires an issuer to keep books, records and accounts that accurately and fairly reflect its transactions, and bars anyone from knowingly circumventing its internal accounting controls or falsifying a record. The SEC case turned on exactly that.

For a bank, a hush payment routed through a third party and described as a fee looks like any concealed payment. FinCEN lists third parties that shield a public official's identity among its corruption red flags, and the questions carry over: who paid, who received, and why the documents say otherwise.

Which 2026 verdicts and rules touch bribery proceeds?

• 19 February 2026. The Justice Department announced the jury's conviction of the former Corsa Coal vice president on FCPA and money laundering counts and a wire fraud conspiracy count.
• 29 April, 11 May and 31 May 2026. Directive (EU) 2026/1021 was adopted, published in the Official Journal and entered into force.
• 1 May 2026. A judge approved the SFO's deferred prosecution agreement with Ultra Electronics over failure to prevent bribery: a £10 million penalty plus £4.8 million in costs.
• 6 August 2026. A jury convicted the former Goldman banker; sentencing was set for 10 November 2026.

Bribery and laundering stay two crimes, and the official's side now has an offense of its own in US law: under FEPA, an official who takes a bribe from a US issuer or domestic concern faces a charge written for that act. Once member states transpose Article 10 by 1 June 2028, hiding a bribe becomes a concealment offense across the EU but Denmark. A bank holding the accounts still has to establish whose money it is and what it paid for.