Ambiguity Around 'Business Routine Practices' in the Guidance

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.