Bribe, Swindle or Steal Where’s the Cavalry: Global Anti-Corruption Efforts
Sep 24, 2025
Nicola Bonucci, an Associate Professor at Paris Cité and former General Counsel of the OECD, shares insights from his 25 years of anti-bribery expertise. He discusses the evolution of the OECD Anti-Bribery Convention, highlighting shifts in enforcement dynamics and the U.S.'s fluctuating role. Nicola warns of rising risks for companies amid evolving political landscapes and nebulous guidance on business practices. He emphasizes the importance of strong compliance programs as multijurisdictional enforcement becomes more common, particularly with new alliances forming in the UK, France, and beyond.
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U.S. Dominance In Early Enforcement
- The U.S. initially dominated foreign bribery enforcement after the OECD Convention came into force around 2000.
- Other countries were slow to prosecute while US prosecutors filled the enforcement gap.
Shift Toward Multilateral Enforcement
- From 2010 to 2020 enforcement rebalanced as other countries built institutions and cooperated with the U.S.
- Multi-jurisdictional settlements and DPAs spread as enforcement became more collaborative.
Global Adoption Of Cooperation Tools
- Recent years saw greater focus on self-disclosure, cooperation, and DPA-style tools globally.
- Many non-US authorities adopted approaches inspired by US creativity and tools.