In a previous piece in conversation with Severin Wirz, ethics and compliance attorney (and former TRACE staffer) about his book Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act, I covered his telling of the pre-history of the FCPA. In this second of a two-part series, I explore how Wirz thinks the anti-corruption movement should now move forward, particularly following first the FCPA pause, and now the changes in FCPA enforcement.

When enforcement of the Foreign Corrupt Practices Act (FCPA) was paused in February 2025, ethics and compliance attorney Severin Wirz, previously with TRACE and now at Applied Materials, was finalizing a 10-year project on the law’s history. His resulting November 2025 book, Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act, truly meets this current moment. In this first of a two-part series from our recent conversation, I examine Wirz’s recounting of the

Estimating the global volume of illicit financial flows stemming from tax evasion, laundering criminal proceeds, terrorist financing, financial fraud and corruption is an inexact science. The UN once estimated that 2%-5% of global GDP, or $800 billion - $2 trillion is laundered annually; in 2018, the IMF offered a range of $1.6-$4 trillion; in January 2024, Nasdaq gave an estimate of $3.1 trillion.

It is cliche to say that artificial intelligence will impact nearly every industry, bringing changes both predictable and not. The question of how AI is affecting the anticorruption space has been covered by BriberyMatters, including these pieces on learning; these on the opportunities and risks of using AI in compliance programs; and several of my own touching on how AI intersects with procurement reform and the importance of data reliability.

We are reposting an article as part of the debate about the value of the ISO anti-bribery compliance standard. This was first published when the ISO standard was released, but we believe it remains a relevant part of the debate today.

For the past two decades, compliance has been defined by scale. Robust programs, multilayered policies, and sophisticated monitoring tools are all hallmarks of a well-managed compliance program. Yet, as this series revealed, resiliency is not a result of size but rather a product of connection. Small and medium-sized enterprises (SMEs), which form the backbone of many economies, can leverage their small size into an advantage. These SMEs will shape the future of compliance.