The past 30 days have brought interesting changes to the world of anti-corruption enforcement. Of course in the United States there was the Yates Memo, directing prosecutors to seek to indict more individuals in white-collar crimes such as the Foreign Corrupt Practices Act. At the end of the day, however, two developments in Europe may stand out further in the ongoing fight against bribery and corruption than even the Justice Department’s newly found focus on individuals and senior executives.
