Fraud Prevention and Detection

APPENDIX A: SUMMARY OF RED FLAGS

263

• Unusually high fees for legal services

• No recognizable service provided by foreign agent or consultant

and no record of service delivery

• Unusually high fees paid for the services rendered

• Winning bids, where products are not invoiced directly to the

principal purchaser on record for the tender

• Marked uctuation in marketing expenses

• Increases in commission expenses when the use of agents is

rst introduced

• Advances to subcontractors or joint venture partners in the

absence of contracts, but within short time of a winning bid

• Permitting nongroup importers to bid for contracts while such

permission is contrary to corporate policies in other markets

MARKET MANIPULATION AND START- UP

CORPORA