Tender capture by organised crime or politically exposed networks
Organised crime, coercive networks or politically exposed groups capture the tender process through intimidation, collusion or control of subcontracting and supply chains.
Red Flags & Indicators
- Bidders, evaluators, or community stakeholders report intimidation, threats, or coercion linked to participation in tender or award outcomes.
- A small set of networks dominates key inputs (materials, logistics, labour, supply chains), and competitors face barriers unrelated to capability.
- Extortion demands or “protection” arrangements emerge during the tender process, sometimes accompanied by security incidents.
- Unusual access control throughout the tender process and the presence of tender “gatekeepers”.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes higher security and operating costs; distortions in bidding and subcontracting; heightened safety risks to personnel and project sites; anti-bribery and AML exposure when “protection” payments are solicited; and reputational risks associated with captured supply chains.
Decision Point
During the tender process, assess signs of intimidation and coercion, and request a documented security and reporting plan.
Mitigation Actions
• Obtain internal compliance approval before engagement with partners, subcontractors, and suppliers
• Require transparent subcontracting and traceable payments
• Ban/reject cash payment and engagement with undisclosed related parties
• Monitor subcontract award changes
• Implement a security incident and intimidation reporting protocol (site access controls, escalation routes, protected reporting), and maintain a documented track record of cases and supporting evidence
• Use internal compliance escalation processes and whistleblower channels, where available, to report signs of organised-crime, intimidation and coercion
• Refer concerns of organised-crime or coercion to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Escalate and suspend/exit where credible organised-crime or coercion indicators persist
• Recommend that procuring entities use independent monitors and observers in high-risk tenders
Mitigation Resources
Require partners, subcontractors, suppliers, and other third parties in the bid and subcontracting chain to comply with anti-corruption and integrity requirements; require transparent subcontracting, traceable payments, disclosure of lower-tier arrangements, and reporting of coercion, intimidation, collusion, or organised-crime indicators.
Supplier and subcontractor integrity controls — https://toolbox.infrastructuretransparency.org/resource/supplier-and-subcontractor-integrity-controls/Screen partners, subcontractors, and key suppliers linked to the bid and subcontracting chain; verify beneficial ownership where feasible, PEP exposure, sanctions, adverse media, and related-party risks, and stop or escalate unresolved red flags.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Commit to independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes heightened security, delay and overrun risks; increased risk of sanctions, AML and human rights non-compliance through contractors and suppliers; potential investment suspension or exit if coercion persists; reduced project value due to disrupted delivery; and reputational risk if coercive networks are linked to the project.
Decision Point
At tender and award-linked milestone, verify security and integrity controls, and suspend or exit in the absence of governance mechanisms to mitigate the risk of capture and coercion.
Mitigation Actions
• Require transparent subcontracting and audit/verification rights
• Condition financing on tender integrity controls (secure bid handling, conflicts-of-interest management, disclosure of agents and commissions, security incident and intimidation reporting protocol, track record of incidents and documented responses)
• Treat credible signs of organised-crime, intimidation and coercion as a suspension trigger
• Pause disbursements until incidents are reviewed
• Request that procuring entities use independent monitors and observers for high-risk tenders
Mitigation Resources
Conduct integrity due diligence and issue tracking on high-risk parties in the tender and subcontracting chain; require subcontract transparency, audit or information rights, robust procurement-integrity controls, documented responses to intimidation or extortion reports, and pause support where organised-crime, coercion, or tender-capture risks remain unresolved.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Screen sponsors, key suppliers, subcontractors, and related counterparties in the tender and subcontracting chain; verify beneficial ownership where feasible, PEP exposure, sanctions, exclusion status, adverse media, and related-party risks, and stop or escalate unresolved red flags.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes inability to run fair tenders; inflated costs and compromised quality; higher risk of safety incidents and worker/community harm; limited accountability; legal risks; and loss of public trust if coercion is not confronted.
Decision Point
During the tender process, assess signs of coercion and capture, proceed with protective measures and decide to re-tender if risks persist.
Mitigation Actions
• Maintain an auditable tender file, documenting redactions and decisions
• Apply exclusion and debarment rules consistently
• Require subcontracting transparency and notification of subcontract changes
• Require disclosure of intermediaries, commissions, beneficiaries, payment arrangements and control structures
• Refer credible allegations of organised-crime, intimidation and coercion to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Decide to re-tender when risks of capture, coercion and extortion persist
• Use independent monitors and observers for high-risk tenders
Mitigation Resources
Collect, publish where lawful, and use beneficial ownership data on bidders, agents, intermediaries, and key subcontractors to identify hidden control, affiliated actors, politically exposed networks, and high-risk links in the tender and subcontracting chain.
Beneficial ownership transparency and interoperability — https://toolbox.infrastructuretransparency.org/resource/beneficial-ownership-transparency-and-interoperability/Require disclosure of bidders, key subcontractors, intermediaries, and related counterparties in the tender and subcontracting chain; verify beneficial ownership, PEP exposure, sanctions, and related-party risks, and apply exclusion rules or escalate red flags where permitted.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Publish and maintain public access to key tender integrity records, including ownership and agent declarations, subcontracting disclosures, exclusion or debarment decisions, and reasons for related decisions, to support external scrutiny and audit.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes increased violence and community harm; barriers to transparency and accountability; higher intimidation and retaliation risk for reporting; captured supply chains; increased risks of labor and safety abuses; and loss of public trust in public institutions.
Decision Point
During the tender process, submit access to information to request clarification on agents' and subcontractors' arrangements. Decide whether to (a) escalate through oversight channels to report credible signs of intimidation and capture, or (b) monitor while safely gathering evidence.
Mitigation Actions
• Monitor agents’ and subcontractors' information to identify opaque structures, repeat high-risk actors, and gatekeeper control of key inputs
• Mobilise communities around the importance of full transparency of bidders’ contractual and group relationships to prevent hidden and undisclosed ties
• Support community reporting and safeguarding in high-risk areas
• Engage oversight bodies when signs of organised-crime, intimidation and coercion emerge (use safe, confidential reporting and anonymisation where the risk of retaliation is significant)
• Advocate for independent monitors and observers for high-risk tenders
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Analyse available beneficial ownership, intermediary, and subcontracting disclosures to identify hidden control, affiliated actors, politically exposed links, and high-risk networks in the tender and subcontracting chain.
Beneficial ownership transparency and interoperability — https://toolbox.infrastructuretransparency.org/resource/beneficial-ownership-transparency-and-interoperability/Request access to non-public decision records, such as debarment decisions, enforcement referrals, tender-integrity measures, or records explaining why high-risk bidders, agents, or subcontractors were not excluded or sanctioned, so hidden decisions, missing rationales, or unexplained inaction can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/Review publicly disclosed tender-integrity records, including ownership disclosures, debarments, enforcement actions, and published integrity measures; identify disclosure gaps, missing justifications, or unexplained changes, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/