The Justice Department has increasingly recognized the international aspect of anti-corruption investigations and enforcement. In November, in remarks to the FCPA/OECD Anniversary Conference at the NYU School of Law, Acting Assistant Attorney General Ken Blanco said “The commitment of the signatories to the [OECD Anti-Bribery] Convention is grounded in the recognition of the harms and a collective desire to stand firm against them, united in our efforts. But what makes the OECD Convention so unique, and so effective, is that it not only requires its signatories to affirm their commitment to fighting transnational corruption, or even that they pass laws to do so, but it also encourages cooperation and a collaborative approach. Each of the signatories to the Convention has agreed to abide by strong provisions for mutual assistance, peer evaluation, and systematic monitoring. In particular, the comprehensive peer review process motivates countries to ensure the highest level of compliance with the Convention and to take concrete action to fight foreign bribery and corruption.”

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...