DEFINITION
Facilitation Payment
A facilitation payment is a small payment made to a public official to secure or speed up a routine action to which the payer is already entitled, such as a permit or customs clearance. It is prohibited under most anti-bribery regimes, including the UK Bribery Act.
Facilitation payments are difficult to detect because they are individually immaterial and often correctly recorded, appearing as agent fees, expediting charges, or customs handling costs.
Detection relies on pattern and context rather than amount: small recurring payments to the same intermediaries, concentrated in higher-risk jurisdictions, and clustered around clearance or permitting events.