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.

In December 2025, I wrote about my discussion with Daniel Haberly, an expert in illicit financial flows based at the University of Sussex Centre for the Study of Corruption (CSC), regarding how to map the networks that facilitate flows of corrupt funds around the world. In this second piece from our conversation, I drill down into his 2023 paper Corruption, Shell Companies, and Financial Secrecy: Providing an Evidence Base for Anti-Corruption Policy...

Strategic litigation, the practice of bringing a lawsuit to catalyze some larger systemic objective, is not a new tool in the anti-corruption and anti-kleptocracy arsenal, but for a variety of reasons, it has been comparatively less utilized...

Dealing with unethical behavior and corruption inside your organization is challenging. It requires a mix of leadership, legal acumen, and emotional intelligence. During a crisis, executive, legal, and compliance teams should consider ways to ensure the investigation process acknowledges the human element of an investigation while maintaining integrity. Whether wrapping up an investigation or preparing for a day that never arrives, addressing corruption requires legal precisi

Corruption is a key driver of extreme poverty and inequality throughout the world. While an exact figure remains elusive, the UN estimates that corruption costs $2.6 trillion annually, or 5% of the world's GDP. Corruption is also a destabilizing force that is frequently at the heart of global events.

The Trump administration issued an executive order (EO) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) to prioritize...