Engaging Legitimate Third Parties
It is illegal under international anti-corruption laws to use an intermediary to make improper payments, whether directly or indirectly.
It's your responsibility to perform proper due diligence to make sure that the consultants, partners, or agents involved in a business deal are bona fide and legitimate.
You must never make a payment to any person you believe will pass it on to a government official or client representative.
Conscious disregard or deliberate ignorance will not protect you from penalties for violating international anti-corruption laws. Ignorance is never an acceptable defence.