Globalizing Sanctions against Foreign Bribery: The Emergence of a New International Legal Consensus

Part I of the article begins with a review of the rationale and key legal ele- ments of the U.S. Foreign Corrupt Practices Act. Part II describes recent efforts by the United States to convince other governments and firms of the need for binding, enforceable and universally accepted rules against corrupt payments to foreign public officials. Parts III and IV survey the activities of various governmental organizations and major private sector groups that support international efforts to effectively discourage foreign bribery, re- spectively. The key sections, Parts V and VI, describe, analyze and critique the two major international conventions, the Inter-American Convention Against Corruption, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Finally, Part VII discusses the further steps that must be taken to be sure that this re- cent progress becomes a significant and effective deterrence to foreign brib- ery.