Private Commercial Bribery: The Next Wave of Anti-Corruption Enforcement?

April 15, 2010
Recent actions by American enforcement authorities and an apparently growing international consensus against private commercial bribery suggest that companies should expand their international compliance programs to aggressively prohibit commercial bribery as well as bribery of government officials. This update examines the international trend toward prohibition of private commercial bribery and the tools U.S. authorities might use if they decide to aggressively punish commercial bribery abroad.