By Paul Emanuelli

This article is an excerpt from The Art of Tendering: A Global Due Diligence Guide, which is available for purchase.

While bid-rigging, price-fixing, and collusion may appear to be isolated incidents that occur in other locales far removed from your location, the reality is that these practices are widespread in nature and impact many jurisdictions worldwide. As this discussion illustrates, while recent court cases provide a glimpse into inappropriate contracting practices in public procurement, these court decisions are the tip of the iceberg when it comes to interference, influence peddling, collusion, and price-fixing in public procurement, as reflected by the summary of news reports provided further below.

Some Recent Court Cases

In its February 2016 judgment in Fiji Independent Commission Against Corruption v. Rudra Maharaj, the High Court of Fiji accepted the unanimous finding of a jury and convicted the accused of bribery. According to the evidence brought by the prosecutors, the defendant was an official in the Prime Minister’s Office who had pressured bidders participating in a government tendering process to pay him bribes in the amount of $22,000 (FJD) in order to influence the award of contracts for the construction of biofuel sheds. While the defendant denied the charges, the prosecutors introduced an audio recording in which the accused had demanded payments from the bidders in post-bid meetings.

In its April 2017 decision in United States of America v. Mercer Transportation Co., Inc., the United States District Court upheld multiple damages claims arising out of a bribery scheme involving government contracts. The case dealt with a series of alleged bribes given to Department of Defense officials in exchange for transportation services contracts. The government sought damages in civil proceedings as compensation. The defendant sought to strike out the claims; however, the Court upheld the government’s claims, which included claims for inducing breach of fiduciary duty, as well as claims under the federal False Claims Act and under Georgia’s fraud law.

In its November 2017 decision in The Queen v. Salter, the Supreme Court of Victoria sentenced a contractor to four years and five months in prison for his role in a bribery scheme involving government contracts. The Court found that during the defendant’s participation in the broader conspiracy, 177 contracts were awarded, with a total value of $10,668,037 (AUD), for which the defendant’s company received $1.7 million (AUD). In its sentencing decision, the Court noted that the bid-rigging conspiracy undermined the public interest and that “corruption of this kind strikes at the heart of our civilised democracy.”

In its March 2018 decision in R. v. Carson, the Supreme Court of Canada upheld the conviction of a former senior advisor to the Prime Minister of Canada for influence peddling. As the evidence showed, during the year following his departure from his position as senior advisor to the Prime Minister, Bruce Carson entered into an agreement with H2O, a water treatment company, to use his government contacts to promote the sale of the company’s water treatment systems to First Nations communities in exchange for commissions to be paid to his girlfriend.

However, as noted above, these court decisions represent a small fraction of reported improprieties in the public procurement process.

Newsreel Reflects a Pandemic of Public Procurement Corruption

The following newsreel highlights compiled by The Procurement Office Media Monitoring Team provides an insight into the size and scope of this problem:

On January 6, 2017, in “How Rift Valley Railways bosses inflated tender prices to loot World Bank loan”, StandardDigital reported that a World Bank audit found that Kenyan railway executives “bribed public officials, manipulated accounts and created convoluted ownership and operational structures with the aim of defrauding lenders, including the International Finance Corporation (IFC), the World Bank’s investment arm.” Sanctions remained pending in the wake of this ongoing investigation.

On January 9, 2017, in “Nigeria’s Jonathan named in Italian ‘kickback’ probe”, AFP stated that Italian prosecutors “alleged that Nigeria’s former president Goodluck Jonathan and his oil minister received kickbacks as part of a $1.3 billion [(NGN)] deal involving oil giants ENI and Shell.” Proceedings remained ongoing and no charges were filed at the time of these initial reports.

On January 9, 2017, in “MoI General Gets 14 Years In Prison For Taking A Bribe”, Tolo News reported that an Afghan general was sentenced to fourteen years in prison after “accepting a $150,000 (USD) bribe in exchange for awarding a fuel contract to a private company.” The general maintained his innocence and claimed that he was tortured after his arrest. The Anti-Corruption Criminal Justice Center’s primary court, which had already sentenced another five officials to prison in recent months, issued a summons for six other government officials in relation to the case, including the government’s procurement manager.

On January 19, 2017, in “CCI imposes penalty on firms for bid rigging of rail tender”, The Hindu reported that India’s Competition Commission imposed 2.92 crore (approximately $450,000 in USD) in penalties on three firms for bid-rigging in relation to tenders issued by the Indian Railways. The report noted that the Commission found price-collusion between the firms in question prior to the submission of bids.

On January 27, 2017, in “Feds Intervene in Alleged $20M Ambulance Kickback Scheme”, Bloomberg Law reported that federal prosecutors alleged that a Texas firm paid $20 million (USD) in bribes over a 15-year period to a senior official at the Oklahoma Emergency Medical Services Authority in an alleged kickback scheme involving lucrative ambulance services contracts. The government was seeking treble damages and penalties in compensation for the alleged kickbacks.

On January 30, 2017, in “Odebrecht pulls out of Panama canal bridge tender amid probe”, Reuters reported that Odebrecht, a Brazilian construction firm now under investigation for allegedly paying hundreds of millions (USD) in bribes across Latin America, withdrew its bid to build a bridge over the Panama Canal in the wake of money laundering and bribery charges laid by Panamanian authorities against 17 people, including businessmen and former government officials. The proceedings remained ongoing.

On February 2, 2017, in “Congressional IT Staff Under Investigation In Alleged Procurement Scam”, BuzzFeedNews reported that federal IT support staff were under investigation over a “procurement scam” involving Congressional computer systems. While initial reports of arrests were later corrected, authorities confirmed that the investigation was ongoing.

On February 5, 2017, in “Probe finds potential bid rigging in public transport services”, newstalk 106-108 fm confirmed that the Irish Competition and Consumer Protection Commission was reportedly investigating potential bid-rigging in relation to transportation services tenders. As the story stated, 20 search warrants were granted in support of the ongoing investigation.

On February 21, 2017, in “FBI seizes Atlanta Chief Procurement Officer’s computer”, FOX5 reported that the FBI seized the computer belonging to Atlanta’s former chief of procurement after the official was summarily dismissed from his position in the wake of a controversial decision to cancel the City’s lucrative airport concessions tender. The ongoing FBI bribery investigation already produced two guilty pleas from city construction contractors.

On March 5, 2017, in “You can’t win a contract in Ghana if you don’t pay bribe – Business owners”, JoyOnline reported that two local business owners raised allegations of rampant bribe taking. They claimed that public officials forced contractors to inflate prices to cover the cost of the kickbacks. As one owner alleged, “between the acceptance of the contract and payment, he had to go through the hands of more than 40 people who each demanded something.” Ghana’s incoming president pledged to “sanitise the system to flush out persons who want to make money through devious behaviour.”

On March 10, 2017, in “Bombardier employee arrested, others questioned in Swedish bribery probe”, CBC News confirmed that Swedish authorities arrested a Russian national employed by Bombardier Transportation “in connection with contracts for a railway modernization project in Azerbaijan” that was financed by the World Bank. The arrested individual, who was charged in the alleged bribery scheme, was considered a flight risk and held in custody. Bombardier maintained that it was co-operating with authorities.

On March 24, 2017, in “Councillor wants paving companies ‘blacklisted’ after AG probe finds apparent bid-rigging”, CBC News reported that the City of Toronto’s Auditor General released a series of recommendations for dealing with the municipal price-fixing scandal that impacted “$1 billion [(CAD)] worth of construction contracts every year”. Those recommendations included maintaining a database of bid and contract information to monitor for potential collusion, training staff on bid-rigging prevention, and maintaining the anonymity of companies that request bid documents in order to stifle pre-bid collusion.

On April 28, 2017, in “OPP probing suspected Toronto city bid rigging”, The Toronto Star reported that the Toronto Auditor General called for a police investigation into suspicions of widespread bid-rigging. Her report raised concerns over ongoing collusion by construction companies bidding on municipal paving contracts. The Auditor General noted that her investigation was hampered by the City’s paper-bound bidding process and that she “was surprised to discover contractors submit bids only on paper.” As the story states, “her staff had to borrow a van from the city clerk’s department, drive to city district offices collecting paper records and then develop spreadsheets that allowed them to analyze trends and discover the signs of collusion.”

On April 28, 2017, in “Ex-Chicago schools head gets prison in kickback scheme”, The Detroit News reported that the former head of the Chicago school district, which is the third largest in the country, was sentenced to four years in prison for her role in a $23 million (USD) kickback scheme where “she steered city contracts to education firms for a cut of more than $2 million in kickbacks.” The judge said that “her brazenness in bilking an already cash-strapped school district suggested she never believed she’d get caught in a city with a long, ignominious history of corruption”, and that “the scheme diverted money from low-income students relying on education to better their lives.”

In a May 2017 report out of London entitled Crackdown on Bid-Rigging in Belgian Railway/Power Sector, Watson Farley and Wilson reported that the “Belgian Competition Authority (the “BCA“) has broken up a cartel between five energy firms for manipulating bids in a public contract issued by Belgium’s railway infrastructure manager, Infrabel. All five companies could face follow-on damages claims, which should act as a stark reminder of the importance of having robust competition compliance measures in place.” The report noted that some of the companies had already applied for leniency in exchange for smaller financial penalties.

On May 2, 2017, in “Crown corporation at risk of procurement fraud”, says auditor general, CBC News reported that Canada’s Auditor General warned that Defence Construction, an agency that awards $1 billion (CAD) in military construction contracts annually, had outdated fraud detection systems. As the report stated, “The corporation had rudimentary fraud-detection systems, which were manual and implemented regionally…Management was therefore unable to use the systems to detect and analyze broader trends that might reveal fraud (such as bid-rigging) that could be spread out over time, across regions, or among many suppliers.”

On May 17, 2017, in “Barrie manager, Innisfil contractor handed house arrest for kickback scheme”, reported that a former municipal manager and a local contractor were both sentenced to 15 months house arrest, 12 months probation, and 150 hours of community services, and were also ordered to pay a total of $127,000 (CAD) in restitution, after pleading guilty to a kickback scheme. As the Court noted, the scheme created an uneven playing field where the contractor was able to low-bid his competitors to win contracts and then increase his price after award with the assistance of his inside accomplice.

On May 24, 2017, in “Five Naples mafia suspects held in bid-rigging sting”, Business Standard reported that police authorities arrested five people and seized assets valued at 70 million euros as part of an investigation into an alleged intimidation and bid-rigging ring. As the story states, an organized crime clan allegedly infiltrated local companies as a cover for its larger money laundering operations.

On May 28, 2017, in “Investigation of helicopter procurement graft might target higher officials”, The Jarkata Post stated that Indonesia’s military commander announced that several high-ranking air force officers were under investigation in relation to a helicopter deal involving a British-Italian company that resulted in $16.5 million (USD) in markups for the costs of the helicopters. As the story stated, “the three suspects could be charged with insubordination, misuse of authority, embezzlement and forgery.”

On June 1, 2017, in “Collusion put floor under bids for carpeting contracts”, The Irish Times reported that a five-year prosecution successfully resulted in bid-rigging sentences for a price-fixing ring in the commercial flooring sector. The scheme inflated prices in large multinational contracts tendered by corporations including Google, MasterCard, and Paypal. The investigation was initially triggered by a whistleblower. The prosecution was subsequently aided by an informant who called the government’s “immunity line” and surrendered as a state witness to avoid prosecution.

On June 4, 2017, in “‘Criminal fronting’, bid rigging in Prasa train deal – court”, news24 in Johannesburg reported that a judge struck down a contract award in a train tender after finding that the winning company was a “criminal front”. As the story stated, “In one of the harshest legal condemnations of a public tender in recent years, the Court found that international manufacturing giant General Electric would have won the tender had Prasa’s “corrupt tender process” not been specifically tailored in order to favour Swifambo’s bid.” In setting aside the contract award, the judge referred to corruption as a “cancer that is slowly eating the fabric of our society.”

On June 10, 2017, in “Vallejo city employee arrested for alleged kickback scheme”, the Times-Herald reported that a Vallejo municipal employee was arrested over an alleged kickback scheme. As the report stated, the city’s landscape manager “is accused of misusing federally funded Community Development Block Grant program monies by offering a business owner additional work with the city in exchange for a 10 percent cut.” The business owner contacted the FBI after the alleged shakedown attempt and assisted in the resulting investigation. To avoid detection, the manager had apparently engaged in contract-splitting to keep awards within his delegated authority.

On June 16, 2017, in “Federal corruption probe casts wide net in New York”, the Poughkeepsie Journal reported that a federal bid-rigging probe recently led to the indictment of Governor Cuomo’s former top aid as part of an investigation that covered “all corners of the Empire State, netting documents from City Hall in Rochester to the furthest tip of Long Island and beyond.” Court documents filed by federal prosecutors provided “a new glimpse into the major bid-rigging probe that shook Cuomo’s administration last year.” The prosecution involves allegations of bid-rigging in state contracts valued in the hundreds of millions of dollars (USD).

On June 25, 2017, in “Asia gets tough on shady business dealings”, the Nikkei Asian Review noted that from “the Philippines to Hong Kong to India, Asian governments are trying to boost economic development by cracking down on cartels, bid rigging and other anti-competitive business practices.” The story referred to several recent high-profile prosecutions involving tenders in industries as varied as technology and railways, to motorcycles and automobile tires, and noted how higher fines are a reflection of increasing attempts to deter corrupt tendering practices.

On June 28, 2017, in “Seven companies charged in Free State tender collusion case”, BusinessDay confirmed that the Competition Commission “formally charged seven Bloemfontein-based companies with colluding and fixing prices.” As the report stated, the “companies‚ amongst other things‚ quoted the same prices for various stationery items in their bills of quantities.” Charges are proceeding in four separate prosecutions.

On July 11, 2017, in “Update: Thirteen plead guilty in Laval collusion probe”, the Montreal Gazette reported that 13 defendants pleaded guilty to price-fixing in connection with municipal construction contracts awarded by the City of Laval. As the story stated, “Eight contractors and five engineers admitted their guilt to three counts of conspiracy, fraud and corruption.” The guilty pleas were part of larger investigation and the individuals “were among the 37 persons arrested during Projet Honorer, a police probe of a system of collusion in municipal contracts between 1996 and 2010.”

On August 9, 2017, in “Prosecutors indict construction firms, officials over bid rigging”, Yonhap News Agency reported that South Korean authorities laid charges against “10 construction firms and 20 officials for fixing a dozen biddings for mega public utility projects worth 3.5 trillion won (US$2.83 billion).” As the story detailed, the “probe was launched early this year after the country’s anti-trust watchdog filed a complaint requesting an investigation into the suspicions.”

On August 10, 2017, in “Former Miami Schools Foreman Accused of Bid Rigging”, Miami Patch reported that a former electrical foreman with the Miami-Dade County Public School Board “was charged with a federal bribery offense following an investigation into lighting purchases by district schools.” As the story stated, “The 52-year old allegedly leaked confidential bid information to a friend who owned a lighting company and accepted thousands of dollars in return over a two-year period.” If convicted, the defendant faces up to five years in prison and a fine of up to $250,000 (USD).

On September 19, 2017, in “Quebec corruption unit arrests seven — including former councillor — in connection to kickback scheme”, the National Post reported that bid-rigging charges were laid against seven people, including a former Montreal councillor. As the story stated, the individuals were “arrested Tuesday and charged with running a kickback scheme whereby engineering companies would be awarded city contracts in exchange for political donations and other favours.” The story also noted that Quebec’s anti-corruption unit “targeted about 30, mainly engineering contracts valued at $160 million [(CAD)], awarded by the City of Montreal between 2001-09”.

On September 23, 2017, in “LEDAC to focus more on curbing corruption in procurement process”, Interaksyon reported that the Philippine executive has agreed to put “greater focus on curbing corruption in the procurement process.” Government officials quoted in the story underscored the importance of “drastically reducing bureaucratic red tape by simplifying regulations and making them more transparent to minimize the opportunities for corruption.”

On October 4, 2017, in “Auditor general says Nova Scotia government needs to tighten its fraud controls”, the National Post reported that the Nova Scotia Auditor General raised concerns over a lack of fraud detection in government bodies and concluded that “the provincial government needs tighter controls on potential fraud by senior public officials who have access to taxpayers’ money.” The audit found that “88 per cent of public organizations in Nova Scotia have not completed an assessment to determine the risks of fraud.” Furthermore, the report noted that “tips account for 40 per cent of all fraud discoveries and the use of fraud tip hotlines can be an effective tool”, as demonstrated in other provinces.

On October 19, 2017, in “Maryland water utility sues chemical companies over alleged price-fixing”, The Washington Post reported that Maryland’s largest water utility launched legal proceedings “against eight chemical companies and five executives, alleging that they conspired to inflate the price of a water treatment chemical over more than 14 years.” The story stated that the alleged price-fixing scam reportedly resulted in millions in additional costs, noting that “68 similar civil claims have been filed against the companies and some of their top executives by water utilities, cities, and private entities, trying to recoup lost money.”

On November 28, 2017, in “Singapore F1 contractor fined over S$570,000 for bid-rigging”, Today reported that a contractor for the Formula 1 Singapore Grand Prix was fined more than S$570,000 (SGD) by the competition watchdog “for rigging the bids of two tenders – providing electrical services for the race and separately, offering asset tagging services for an international school.” The report noted that “an anonymous source sent the Competition Commission of Singapore (CCSC) a tip-off on bid rigging, which turned out to be masterminded by the Cyclect Group.”

On January 18, 2018, in “California Computer Exec Pleads Guilty to Fixing State Bids”, US News & World Report reported that a “Northern California computer expert has pleaded guilty to fixing bids for state contracts”, “pleaded guilty to one count of bid rigging”, and “faces a maximum sentence of 10 years in prison and a $1 million [(USD)] fine when he is sentenced in April.” As the report detailed, the individual “conspired with two competitors to submit inflated bids” to ensure that his computer security company won the contracts with the lowest bids, and that his company reportedly “won 40 state contracts in this fashion.”

On February 6, 2018, in a press release entitled “School Bus Company Owners Sentenced to Prison for Bid Rigging and Fraud Involving Puerto Rico Public School Bus Services”, the United States Department of Justice confirmed that “Four owners of school bus transportation companies were sentenced today for participating in bid rigging and fraud conspiracies related to school bus transportation contracts in Puerto Rico” and that a “jury found that they conspired to rig bids and allocate the market for public school bus transportation contracts in the municipality of Caguas from approximately August 2013 until May 2015.”

On March 11, 2018, in “8 firms fined over bid rigging”, Yonhap News Agency reported that South Korea’s antitrust watchdog “levied a combined 5.9 billion won (US$5.5 million) in fines on eight firms for allegedly rigging bids” and that the companies were “accused of colluding in 28 bids worth 37.4 billion won for the supplying of liquefied petroleum gas (LPG) to the Army, according to the Fair Trade Commission (FTC). The products were supplied to state-run corporations between 2007 and 2013.”

On April 12, 2018, in “Local politician handed 15-year jail sentence in kickback case”, Focus Taiwan reported that a “former mayor of Gangshan Township in southern Taiwan’s Kaohsiung City will serve a 15-year-and- four-month jail term after Taiwan’s Supreme Court rejected his appeal in an illegal kickback case.” The report confirmed that the former mayor entered into an agreement “to take kickbacks from businesses looking to secure contracts for the township’s infrastructure development.”

On May 2, 2018, in “Collusion and bid-rigging! CCI slaps fine on 6 companies for cartelization”, the Financial Express reported that India’s Competition Commission “imposed a total penalty of more than Rs 3.5 crore on six firms and some of their executives for cartelisation.” The case involved bid-rigging and collusion on five tenders issued by the Pune Municipal government for municipal organic and inorganic solid waste processing plants.

On May 4, 2018, in “Couple admits to Fort Gordon bid rigging in $20 million conspiracy case”, the Augusta Chronicle reported that an “Army colonel and his wife admitted to participating in a $20 million [(USD)] bid-rigging conspiracy, taking bribes to steer contracts in the building and modernization of the Army’s information and communications network.” The reported noted that at the material time, one of the individuals “was in charge of overseeing the building and modernization of the Army’s information and communications network at Fort Gordon.”

On May 18, 2018, in “N.Y. developer pleads guilty ahead of ‘Buffalo Billion’ corruption trial”, Reuters reported that a “former executive at an upstate New York developer pleaded guilty and agreed to co-operate with federal prosecutors in a corruption case against a former state university official and others over a $1 billion [(USD)] government project.” According to the report, the executive admitted “to wire fraud and conspiracy charges before US District Judge Valerie Caproni in Manhattan, less than a month before a scheduled trial” and “said he was involved in a bid-rigging scheme that allowed his company to win a lucrative contract as part of ‘Buffalo Billion,’ a signature economic development project of New York Governor Andrew Cuomo to revitalize the region around Buffalo, New York.”

On June 13, 2018, in “Quebec concludes deals worth $95 million in corruption reimbursement”, The Globe and Mail reported that “Quebec has reached deals to get $95 million [(CAD)] in a voluntary redemption program aimed at recouping cash lost to corruption, collusion or bid-rigging in the awarding of public contracts.” As the reported detailed, the “program began in November 2015 and was created in the wake of Quebec’s corruption inquiry, known as the Charbonneau Commission” and “ran until December 2017 and was designed to enable municipalities, school boards or Quebec government departments or agencies to be repaid money they were overcharged over 20 years.” The report further stated that to date, “$75 million has already been repaid and that agreements have been reached with 31 individuals and businesses”.  The report also noted that the provincial program did not extend to federal government contracts and that the “program was cost-neutral to taxpayers as the companies paid an additional 10 per cent of their reimbursement to cover program costs.”

On July 17, 2018, in “Cuomo will donate contributions at center of recent trials”, Politico reported that New York State Governor Andrew Cuomo “is giving up more than a half-million dollars [(USD)] in campaign donations that played a role in two recent trials involving former allies.” The report stated that “Cuomo, after the 2016 arrest of one-time gubernatorial aide Joe Percoco, had said he’d lay aside donations from sources such as LPCiminelli and COR Development after executives at the firms were accused of colluding on a bid-rigging scheme”, and that he “ultimately placed $534,000 in escrow in the event that prosecutors sought its forfeiture.” The report noted that “The money is currently in the process of being donated and will be dispersed in the coming days to groups who do important work on behalf of vital causes: immigrant legal defense, women’s reproductive health rights, and Puerto Rico recovery efforts.”

On July 23, 2018, in “Pharmacy owner gets jail time for $1.5M kickback scheme with NY hospital employee”, Becker’s Hospital Review reported that the “owner of a New York pharmacy was sentenced to six months in jail for participating in a $1.5 million [(USD)] Medicaid kickback scheme with a former hospital employee from East Meadow, N.Y.-based Nassau University Medical Center, according to the New York State Office of the Attorney General.” As the story noted, the “former hospital employee pleaded guilty to unlawfully accepting Medicaid kickbacks earlier in the investigation” and that in addition to the prison sentence, the owner “received five years’ probation” and will be “required to pay $1.5 million in restitution to the state and another $1.5 million in fines.”

On July 22, 2018, in “Council Member Convicted of Bribery, Theft in Kickback Case”, US News & World Report reported that a “suburban Philadelphia borough council member has been convicted of bribery and theft in what prosecutors called a kickback scheme involving security and surveillance equipment.” As the story detailed, “Jurors deliberated all day Friday before convicting former Upland Borough council president Edward Mitchell on theft by deception, criminal conspiracy and bribery counts” and that “Mitchell, 75, received as much as $133,000 [(USD)] in 10- to 15-percent kickbacks on nearly $1 million in security and surveillance equipment installed between 2009 and 2015.”

On July 25, 2018, in “Bid-Rig Guilty Verdict: How Ciminelli Won New York Buffalo Billion Project”, the Engineering News Record reported “a federal jury in New York City convicted on bid-rigging charges the key government and industry players that had been selected to develop and build what was seen as a jobs-producing clean-energy factory in Buffalo, N.Y.” As the reported detailed, the “turning point came when Kevin C. Schuler, LPCiminelli’s vice president, chose in early May to plead guilty to fraud and conspiracy charges and to testify in exchange for a hoped-for lighter sentence. Sitting only a few feet from his former boss at the trial in federal court in Manhattan, Schuler told the jury, ‘We had significant influence over the project, influence over the RFP and influence over the process that was going to select a winner.’” As the report confirmed, the convicted individuals were planning an appeal.

On August 16, 2018, in “Corruption and Crime Commission report uncovers ‘bribes and bid-rigging’ at North Metropolitan Health Service”, reported that health executives “were bribed with travel, boozy lunches and renovations to their homes by contractors looking to secure ‘tens of millions of dollars’ [(AUD)] of work” according to an Australian Corruption and Crime Commission report. The story also stated that kickback scheme was only discovered after a whistleblower made an anonymous tip since “Fear for losing jobs prevented some from speaking out.” The report also stated that “The CCC has recommended authorities consider prosecutions against a number of former Health Department officials as well as contractors.”

On October 5, 2018, in “2 Colorado-based U.S. intelligence officers and a private contractor indicted in alleged $1.5M bid-rigging scheme”, The Denver Post confirmed that “a federal grand jury in Denver has indicted three people — a U.S. Air Force major, a veteran National Security Agency agent and the owner of a private government contractor — in an alleged $1.5 million [(USD)] bid-rigging scheme.” As the report detailed, according to the US Attorney, the “intelligence officers allegedly disclosed bid information on government contracts”.

While these newsreel highlights offer a glimpse into widespread bid-rigging and collusion and show how this corruption is impacting public procurement on a global scale, they are by no means the end of the story. More newsreel highlights are sure to follow in the years to come, which begs the question of whether these stories truly reflect isolated incidents or are just the tip of the iceberg that reflect deeper levels of unreported corruption.