Transparency Int'l Progress Report

Despite the tremendous publicity surrounding global anti-bribery enforcement efforts, including the advent of the UK's Bribery Act and additional substantial fines in the United States and other countries, Transparency International's (TI's) latest Progress Report on global enforcement of the Organization for Economic Cooperation and Development's (OECD's) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the Convention) finds that enforcement “remains inadequate.” See Transparency International, “Exporting Corruption? Country Enforcement of the OECD Anti-Bribery Convention Progress Report 2012″ at 6, www.transparency.org/whatwedo/pub/exporting_corruption_country_enforcement_of_the_oecd_anti_bribery_conventio (hereinafter TI 2012 Progress Report or Progress Report). According to the Progress Report, in most countries that subscribe to the Convention, enforcement is not even at a level that provides a “credible deterrent” to foreign bribery.