TAKEAWAYS
It started with a client lunch.
Marcus, a regional sales director for a Singapore-headquartered manufacturer, had been cultivating a procurement manager at a state-owned enterprise in Southeast Asia for months. The deal was worth S$4 million. His quarterly target depended on it.
The procurement manager mentioned, casually, that his daughter had just been accepted to a Singapore university. Tuition was a concern. Marcus didn’t offer a bribe. He offered to “connect” the family with an education consultant his company sometimes sponsored. The consultant happened to provide a generous scholarship. The contract came through two months later.
Was it corruption? Marcus would say no. He was networking and building relationships; that was how business worked in the region.
The Prevention of Corruption Act would say otherwise.
The most dangerous corruption doesn’t look like corruption. It doesn’t arrive in brown envelopes or offshore wire transfers. It exists in the grey zone – client entertainment that edges past hospitality; “facilitation” that smooths bureaucratic friction; favours exchanged between people who’ve known each other for years.
Most employees who cross lines don’t think of themselves as corrupt. They think of themselves as pragmatic, resourceful, helpful and good at their jobs.
This is the human side of corruption risk, and it’s where most compliance programmes fail.
The test isn’t “Did I mean to bribe?”; it’s “Would a reasonable person see this as influencing a decision?”.
Consider this: A dinner that costs more than a month’s salary for the recipient; a “scholarship” arranged during contract negotiations; golf memberships timed around procurement decisions. The blurring of lines between networking and gratification is where good intentions become legal liability. And it’s precisely this grey zone that compliance programmes must address – not with more rules, but with clearer guidance and better process design.
Corruption is rarely about bad people. It begins with justification, grows with small decisions, and ends with consequences. Integrity is the difference.
In general, there are four pathways that lead good people toward bad choices:
1. Normalisation: The gradual slide
It starts with something small. A coffee, a light meal, an expensive dinner, a festive hamper, a small gift. Perhaps an ang pao, the customary red packet exchanged during Chinese New Year.
Over time, the line blurs. What was once unacceptable becomes accepted. The slide from coffee to cash doesn’t happen overnight. Each step feels marginal, and each rationalisation builds on the last.
2. Pressure: KPIs and work targets
Tight targets create stress. Pressure from superiors can influence actions. Fear of failure can lead to poor judgement.
The rationalisation is predictable: “Everyone does it here.” “I’m just getting things done.” “The company benefits, so where’s the harm?”
When people feel they have “no choice”, they stop asking whether a decision is professional.
3. Conflict of interest: Misaligned loyalties
We want to help, but end up doing the wrong thing.
Personal relationships can influence professional decisions. Consider the vendor who is also a cousin, the supplier who once helped you, the client who has become a friend. Each relationship creates an invisible pull.
4. Organisational culture: “This Is how we do things”
When leaders lead by example, when clear values guide behaviour, when everyone is accountable, good practices become the standard.
But when the culture whispers, “This is how we do things here”, people follow the unwritten rules, not the policy manual. Social pressure to conform can be stronger than any training module.
Here’s what I’ve observed: policies travel well, culture doesn’t. When misconduct surfaces across jurisdictions and over time, it rarely signals just a control gap. Instead, it signals a cultural fracture. What stands out among the organisations that get this right have one thing in common, and that is, boards that treat compliance culture as their responsibility, not a function to delegate. Tone from the top only matters if it reaches the ground.
Sometimes the system creates the shortcut.
Consider a procurement officer at a regional subsidiary. Head office requires three competitive quotes for any purchase above S$10,000. But local suppliers don’t respond to formal RFQs (request for quotations), the approved vendor list hasn’t been updated in two years, and the procurement system regularly crashes.
The officer has two choices, namely, follow the process and miss the deadline, or find a workaround and keep operations running. Most choose the workaround, not because they’re corrupt, but because the process wasn’t designed for their reality.
I call this process-induced non-compliance. The employee isn’t the root cause, the friction is.
While this does not excuse misconduct, it explains why more policies, more training, and more warnings often won’t work. If you don’t fix the process, you’re just adding guilt to the pressure.
Singapore’s Prevention of Corruption Act now reaches beyond its borders. If a Singapore citizen, resident, or company commits a corruption offence anywhere in the world, they can be prosecuted here. Marcus could face charges in Singapore for conduct that occurred entirely overseas.
In April 2026, Singapore’s High Court approved the country’s first Deferred Prosecution Agreement (DPA) with Seatrium, tied to Brazil’s Operation Car Wash probe. There were US$110 million in total penalties.
Singapore credited US$53 million already paid to Brazil, leaving US$57 million payable here. It was not leniency; it was coordination. The “long arm of the law” has become a global handshake between regulators. No longer can you settle in one corner of the world and hope the other will not notice.
The Seatrium case is a reminder that the cost of remediation will always exceed the cost of prevention. Financial penalties, multijurisdictional scrutiny, reputational damage, and more than a decade of remediation effort all point to a simple principle – doing it right the first time is economically rational. But the DPA also reflects something important, namely, accountability and rehabilitation can coexist. Organisations must be held accountable, but also given a structured path to rebuild trust and emerge more resilient.
Most organisations respond to corruption risk with more rules, such as, more sign-offs, more training modules, more declarations. But, the real question should not be “Do our employees know the rules?”; it should be “Do our processes make it easy to follow them?”
This is a design problem, not just a compliance problem.
Finance professionals are uniquely positioned to spot corruption risk, not because you’re investigators, but because you’re trained to be analytical. Patterns, anomalies, inconsistencies … these are the raw materials of your profession.
As auditors: Look beyond the numbers to the process. Ask why approvals were bypassed. Question expenses that feel “off” even if they are technically compliant.
As advisors: Help clients stress-test their processes. Where are the friction points that might tempt shortcuts?
As board members: Oversight must be active, informed, and sustained. Demand clarity on red flags. Be prepared for uncomfortable conversations.
As finance leaders: Own the control environment. Recognise that every process you design either enables integrity or undermines it.
The S$4-million contract that Marcus secured got unravelled two years later when an internal audit flagged the “scholarship” arrangement. The company self-reported, and Marcus lost his job.
Marcus wasn’t a bad person. He was a good salesperson in a system that rewarded results without asking how. The company had policies against bribery; it had training and it had declarations. What it didn’t have was a process designed for the reality of regional business, or a culture that made it safe to say, “I can’t close this deal without crossing a line.”
Most corruption doesn’t start with bad people. It starts with normalisation, pressure, conflicted loyalties, and cultures that look the other way.
Integrity is built through every decision, and its impact lasts forever.
The good news? If the system is part of the problem, the system can be part of the solution.
Part 2 introduces a human-centred design approach to corruption prevention. It includes an Integrity Friction Self Assessment, a tool for finance professionals to evaluate where processes may be creating unintended corruption risk.
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Julia Chin is Founder/CEO, JFourth Solutions.
