AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
The UK Bribery Act 2010 applies to British citizens and anyone ordinarily resident in the UK even when everything happens in Nigeria. Bribing a foreign public official, directly or through an agent, is an offence carrying up to 10 years in prison. Facilitation payments to speed up routine official tasks are bribes with no exemption, but official, legally required fees and fast-track services are allowed, and reasonable hospitality is not prohibited.
Diaspora consultants working in Nigeria are sometimes asked for money that is not on any official schedule: to release a file, to get a signature this week, to "see" the right person. The request may be framed as normal. Under UK law it can be a crime, and the law follows you. This guide sets out the offences, how far they reach, and how to handle the requests consultants actually get.
The four offences
The Ministry of Justice guidance (updated January 2025) lists four offences in the Act:
- Offering, promising or giving a bribe (section 1).
- Requesting, agreeing to receive or accepting a bribe (section 2).
- Bribing a foreign public official (section 6).
- A commercial organisation failing to prevent bribery by people performing services for it (section 7).
Section 6 is the one most relevant to work with Nigerian agencies. It is committed where you intend to influence an official in their official capacity, intend to obtain or keep business or an advantage, and offer, promise or give a financial or other advantage, directly or through a third party, that the official is not permitted or required by written law to be influenced by.
Why it applies in Lagos and Abuja
Section 12 covers acts done wholly outside the UK if the person had a close connection with the UK at the time. The list includes British citizens and other British nationality categories, individuals ordinarily resident in the UK, bodies incorporated in the UK, and Scottish partnerships. So a Nigerian citizen who lives and works in London on a visa is likely to be caught as ordinarily resident, not only British passport holders. A UK limited company you consult through is also covered.
Penalties are set in section 11: for an individual, up to 10 years' imprisonment, a fine, or both on conviction on indictment.
Facilitation payments: no exemption
The MoJ quick start guide is direct: facilitation payments, "payments to induce officials to perform routine functions", are bribes, and there was no exemption for them under the old law and there is none under the Bribery Act. The same guide draws the line you need: you can continue to pay legally required administrative fees or fast-track services. The test is whether the payment is official, published and receipted, and goes to the institution rather than the person.
Common requests and how to handle them
| Request | Risk | What to do |
|---|---|---|
| Official expedited-processing fee, paid to the agency with a receipt | Allowed: a legally required or fast-track fee | Pay through the official channel, keep the receipt |
| Cash to a desk officer to "move your file" | A facilitation payment, so a bribe | Decline, ask for the official process and timeline |
| A local fixer charges a large "logistics" fee with no breakdown | Possible bribe through a third party | Ask what it covers, get a written scope and invoice, walk away if it is unclear |
| Dinner for the project team after a workshop | Hospitality is not prohibited if reasonable and proportionate | Keep it modest and recorded, avoid timing it around a decision |
| An official asks you to hire a relative | An "other advantage" can be a bribe | Decline, or follow a documented open recruitment |
The guide says investigators would look at the level of hospitality, how it was provided, and the recipient's influence over the decision. Lavish gifts near a contract award look very different from refreshments at a meeting.
If you trade through a company
Section 7 makes a commercial organisation liable if someone performing services for it, such as an employee, agent or sub-consultant, bribes to get business for it. The defence is having adequate procedures. The MoJ guidance builds these on six principles: proportionality, top-level commitment, risk assessment, due diligence, communication and monitoring. For a small, low-risk business, the quick start guide says relatively minimal procedures will do, and in a micro-business "simple oral reminders to key staff" may be enough. It suggests practical checks: internet searches on agents, asking for a CV, accounts or references and checking them, and using your normal expense and contract controls.
A one-page policy that fits a small consultancy
- No payments to officials except published fees, paid to the institution, with receipts.
- Agents and fixers sign a written scope and an anti-bribery clause, and invoice for named services.
- Gifts and hospitality are modest, recorded, and never timed around a decision.
- Any request for an informal payment is written down with the date and who asked.
Reporting
The MoJ guidance says suspected bribery should be reported to the police first, and that the Serious Fraud Office and the National Crime Agency's International Corruption Unit lead on international bribery. This is general information, not legal advice; if a payment has already been made, speak to a solicitor before doing anything else.
For the procurement and tax side of government work, see consulting for a Nigerian government agency and contractor agreements with Nigerian clients.
Where Pryme fits
Clean records are the best protection. In a Pryme Business Account every payment carries its reference, and you can issue a verifiable receipt through our partner VerifyDoc.ai. The Compliance agent can keep fee receipts and agent contracts together, with a person approving payments above a ceiling you set.
Questions people ask
Is a small payment to speed up paperwork in Nigeria legal under UK law?
No. The MoJ guide says facilitation payments are bribes and there is no exemption. Official, legally required fees and fast-track services paid to the institution are fine.
I am Nigerian, living in the UK on a visa. Does the Bribery Act apply to me?
Section 12 covers individuals ordinarily resident in the UK, not only British citizens, for acts done outside the UK.
Can I take Nigerian officials to dinner?
The MoJ guide says hospitality is not prohibited if it is reasonable and proportionate. Keep it modest, recorded and away from decision points.
What is the maximum penalty?
For an individual, up to 10 years' imprisonment, a fine, or both on conviction on indictment (section 11).
Sources
- legislation.gov.uk: Bribery Act 2010, section 6 · accessed Oct 2026
- legislation.gov.uk: Bribery Act 2010, section 12 (offences abroad) · accessed Oct 2026
- legislation.gov.uk: Bribery Act 2010, section 11 (penalties) · accessed Oct 2026
- GOV.UK (Ministry of Justice): Bribery Act 2010 guidance (updated 22 Jan 2025) · accessed Oct 2026
- Ministry of Justice: Bribery Act 2010 quick start guide · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.