Croesus Ltd (Croesus), an Australian registered gold mining company, plans to acquire gold leases in Zambia, which is ranked as highly corrupt by Transparency International. Croesus creates a new foreign subsidiary in Cayman Islands called Moro Limited, for the purpose of entering into the gold mining market in Zambia. Fastagus is an Australian national living in Cayman Islands and a non-executive director of Croesus. Given Fastagus' political connections to Zambia, Moro Limited hires Fastagus as an advisor for its new business in Zambia. Moro Limited agrees to pay Fastagus an annual retainer of US$500,000 and a US$1million commission for every lease that is granted to Moro Limited. At a meeting in Melbourne, Australia, Fastagus hires Iris, the wife of the Minister of Mining of Zambia. Fastagus agrees to pays Iris a salary of US$100,000 with a commission of US$700,000 for every lease that Moro Limited secures in Zambia. This meeting is also attended by senior executives of Croesus who give their approval to this arrangement. Jonathan, an Australian national who is also the Chief Financial Officer of Croesus, authorises a payment of US$100,000 to Lonzo, a public official in the Department of Customs and Border Control in Zambia to facilitate the 'quick entry' of mining equipment into Zambia. The mining equipment is used by Moro Limited to explore potential mining sites. Jonathan makes a record of the US$100,000 payment describing it as "consultation expense". The Department of Mining awards Moro Limited ten gold mining leases in Zambia. Subsequently, Moro Limited pays a commission of US$10 million to Fastagus, while Fastagus pays Iris a commission of US$7 million. SPECIFIC QUESTION What is the risk that any person has committed criminal offence(s) under Australian law? You should refer to the provisions in the Criminal Code 1995 (Cth).