The Emerging Global Standard for Effective Anti-Corruption Compliance: Meeting the Expectations of Governments Worldwide

While expansive enforcement of the U.S. Foreign Corrupt Practices Act and the 2011 entry into force of the UK Bribery Act have received the greatest amount of attention, multinational corporations are also subject to anti-corruption laws wherever they do business. Designing an effective anti-corruption compliance program that meets the requirements of many different laws may at first appear nearly impossible to achieve. A comparison of laws from various jurisdictions, guidance issued by various responsible authorities, and guidance gleaned from settlement agreements and relevant private organizations, however, leads to a different conclusion: there is now a broad emerging global consensus on what governments expect for compliance programs. This global standard for effective anti-corruption compliance programs contains common elements and standardized responsibilities.

This advisory reviews the core anti-corruption compliance program elements that form the basis of this global standard and discusses the foundations of an effective anti-corruption compliance program that need to reflect these key elements.