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Phase 3 Report on the U.S. by OECD Working Group on Bribery in International Business Transactions

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Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendations on Combating Bribery in International Business Transactions. This report was approved and adopted by the OECD Working Group on Bribery in International Business Transactions on 15 October 2010.

  • “The Phase 3 Report on the United States by the OECD Working Group on Bribery in International Business Transactions (Working Group) evaluates and makes recommendations on implementation by the United States and enforcement of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Anti-Bribery Convention) and related instruments. The Working Group commends the United States for its visible and high level of support for the fight against the bribery of foreign public officials, including engagement with the private sector, substantial enforcement, and stated commitment by the highest echelon of the Government. Since Phase 2, U.S. enforcement has increased steadily and resulted in increasingly significant prison sentences, monetary penalties and disgorgement. Increased enforcement was enabled by the good practices developed within the U.S. legal and policy framework, including the dedication of resources to specialised units in the Department of Justice (DOJ), the Federal Bureau of Investigation (FBI) and the Securities and Exchange Commission (SEC). New legislation has also strengthened accounting and auditing standards, including those introduced in the 2002 Sarbanes-Oxley Act, covered in the U.S. Phase 2 written follow-up report, and whistleblower protections under the July 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act.”
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