Recent Shifts: Guidance, Politics, and Uncertainty

At the 2025 TRACE Annapolis Forum, Nicola Bonucci, Associate Professor at Paris Cité and former General Counsel of the OECD, reflects on 25 years of the OECD Anti-Bribery Convention and the evolving challenges of global enforcement. From uncertainties around FCPA guidance, political influence, and uneven implementation, to questions about the U.S.’s continued leadership in anti-bribery efforts, Nicola highlights the risks companies face in an increasingly unpredictable landscape—where cross-border investigations, bribe solicitation, and public scrutiny are on the rise.