Cooperation – The MVP in the Corruption Investigation Toolkit

International cooperation among countries investigating corrupt practices has now become the standard, with a continued presumption of collaboration as the world faces heightened threats to financial markets and geopolitical pressures impacting the ethical rule of law.

One organization that has played an instrumental role in encouraging governmental cooperation at the global level is the Organization for Economic Cooperation Development (OECD). Taking an active role in encouraging governments around the world to work together to find solutions to common problems including corruption, the OECD established a Working Group on Bribery in International Business Transactions in 1994. Providing a forum for global governments and enforcement leaders to address the current state of anti-corruption initiatives and anti-bribery enforcement, the Working Group hosts several meetings per year facilitating a direct line of communication between nations. 

An example of what such cooperation can do, in 2022 the U.S. Department of Justice (DOJ) for the first time worked alongside the South African government to reach a settlement with ABB Ltd. for FCPA violations, much of which occurred within South Africa. Similarly, in 2023, the Colombian company, Corficolombiana agreed to pay $80 million as a part of a global FCPA resolution, marking yet another first for the DOJ - the first time the Colombian and U.S. authorities worked together on a foreign bribery case.

The DOJ then announced late last year its investment in a new International Corporate Anti-Bribery Initiative with the intent of increasing relationships with foreign anti-corruption enforcement bodies, creating a mandate for three prosecutors of the DOJ’s FCPA unit who will be purely focused on building more international relationships.

As Principal Deputy Assistant Attorney General Argentieri stated in a speech in 2023, “The Justice Department cannot succeed in combating corruption on our own…strong partnerships and cooperation with our international counterparts is mission critical…law enforcement partners around the world are working together to tackle complex financial crime.”

Cooperation – the new MVP in the corruption investigation toolkit.

Blaise Stanicic

Associate Director, Compliance Training, TRACE