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{{Short description|Activities that oppose or inhibit corruption}}
{{Other uses}}
{{Political_corruption_sidebar}}
{{Use American English|date=October 2018}}
{{Use mdy dates|date=October 2018}}
'''Anti-corruption''' (or '''anticorruption''') comprises activities that oppose or inhibit [[corruption]]. Just as corruption takes many forms, anti-corruption efforts vary in scope and in strategy.<ref name=":0">{{Cite journal |last1=Lehtinen |first1=Jere |last2=Locatelli |first2=Giorgio |last3=Sainati |first3=Tristano |last4=Artto |first4=Karlos |last5=Evans |first5=Barbara |date=2022-05-01 |title=The grand challenge: Effective anti-corruption measures in projects |url=https://www.sciencedirect.com/science/article/pii/S0263786322000576 |journal=International Journal of Project Management |language=en |volume=40 |issue=4 |pages=347–361 |doi=10.1016/j.ijproman.2022.04.003 |s2cid=248470690 |issn=0263-7863}}</ref> A general distinction between preventive and reactive measures is sometimes drawn. In such framework, investigative authorities and their attempts to unveil corrupt practices would be considered reactive, while education on the negative impact of corruption, or firm-internal [[regulatory compliance|compliance]] programs are classified as the former.

== History ==
=== Early history ===
[[File:Code of Hammurabi 70.jpg|thumb|alt=Photograph of the code of Hammurabi stele as displayed in the Louvre|Among the earliest documented anti-corruption efforts include the [[code of Hammurabi]], dated to around 1754&nbsp;BC.]]
The [[code of Hammurabi]] ({{circa|1754&nbsp;BC|lk=on}}), the [[Horemheb#Internal reform|Great Edict of Horemheb]] ({{circa|1300&nbsp;BC}}), and the [[Arthasastra]] (2nd century&nbsp;BC)<ref>{{cite book |last=Olivelle |first=Patrick |title=King, Governance, and Law in Ancient India: Kauṭilya's Arthaśāstra |year=2013 |publisher=Oxford University Press |location=Oxford UK |isbn=978-0-19-989182-5 |pages=30–31 |language=en }}</ref> are among the earliest written proofs of anti-corruption efforts. All of those early texts are condemning bribes in order to influence the decision by civil servants, especially in the judicial sector.<ref>Bacio Terracino (2012), p. 28</ref> During the time of the [[Roman Empire]], corruption was also inhibited, such as by a decree issued by emperor [[Constantine I]] in 331.<ref>{{cite book |last=Noonan |first=John T. |author-link=John T. Noonan Jr. |title=Bribes |page=[https://archive.org/details/bribes00noon/page/90 90] |publisher=Macmillan |place=New York |year=1984 |isbn=0-02-922880-8 |language=en |url-access=registration |url=https://archive.org/details/bribes00noon/page/90 }}</ref>

In ancient times, moral principles based on religious beliefs were common, as several major [[religion]]s, such as [[Buddhism]], [[Christianity]], [[Hinduism]], [[Islam]], [[Judaism]], [[Sikhism]], and [[Taoism]] condemn corrupt conduct in their respective religious texts.<ref>Bacio Terracino (2012), p. 29</ref> The described legal and moral stances were exclusively addressing [[bribery]] but were not concerned with other aspects that are considered corruption in the 21st century. [[Embezzlement]], [[cronyism]], [[nepotism]], and other strategies of gaining public assets by office holders were not yet constructed as unlawful or immoral, as positions of power were regarded a personal possession rather than an entrusted function. With the popularization of the concept of [[public interest]] and the development of a professional [[bureaucracy]] in the 19th century offices became perceived as trusteeships instead of property of the office holder, leading to legislation against and a negative perception of those additional forms of corruption.<ref>Bacio Terracino (2012), p. 30</ref> Especially in diplomacy and for international trade purposes, corruption remained a generally accepted phenomenon of the political and economic life throughout the 19th and big parts of the 20th century.<ref>''Confronting Corruption'', p. 9</ref>

=== In contemporary society ===
{{Globalize|section|date=August 2018}}
In the 1990s corruption was increasingly perceived to have a negative impact on [[economy]], [[democracy]], and the [[rule of law]], as was pointed out by [[Kofi Annan]].<ref>{{cite book |last=Peters |author-link=Anne Peters |first=Anne |editor1-last=Thelesklaf |editor1-first=Daniel |editor2-last=Gomes Pereira |editor2-first=Pedro |year=2011 |chapter=Preface |title=Non-State Actors in Asset Recovery |language=en |publisher=Peter Lang |pages=vii–ix |isbn=978-3-0343-1073-4 }}</ref> Those effects claimed by Annan could be proven by a variety of empirical studies, as reported by Juli Bacio Terracino.<ref>Bacio Terracino (2012), pp.31-34</ref> The increased awareness of corruption was widespread and shared across professional, political, and geographical borders. While an international effort against corruption seemed to be unrealistic during the [[Cold War]], a new discussion on the global impact of corruption became possible, leading to an official condemnation of corruption by governments, companies, and various other stakeholders.<ref>''Confronting Corruption'', pp. 12 et seq.</ref> The 1990s additionally saw an increase in press freedom, the activism of civil societies, and global communication through an improved communication infrastructure, which paved the way to a more thorough understanding of the global prevalence and negative impact of corruption.<ref>{{cite journal |last1=Mccoy |first1=Jennifer L. |last2=Heckel |first2=Heather |date=2001 |title=The Emergence of a Global Anti-corruption Norm |journal=International Politics |volume=38 |issue=1 |pages=65–90 |doi=10.1057/palgrave.ip.8892613 |s2cid=145174166 }}</ref> In consequence to those developments, international [[non-governmental organizations]] (e.g. [[Transparency International]]) and [[inter-governmental organization]]s and initiatives (e.g. the [[OECD]] Working group on bribery) were founded to overcome corruption.<ref>''Confronting Corruption'', pp. 13-14</ref>

Since the 2000s, the discourse became broader in scope. It became more common to refer to corruption as a violation of [[human rights]], which was also discussed by the responsible international bodies.<ref>{{cite book |last=Boersma |first=Martine |date=2012 |title=Corruption: A Violation of Human Rights and a Crime Under International Law? |publisher=Intersentia |isbn=978-1-78068-105-4 |pages=358 }}</ref> Besides attempting to find a fitting description for corruption, the integration of corruption into a human rights-framework was also motivated by underlining the importance of corruption and educating people on its costs.<ref>{{cite book |last1= Sepúlveda Carmona |first1=Magdalenda |last2=Bacio-Terracino |first2=Julio |editor1-last=Boersma |editor1-first=Martine |editor2-last=Nelen |editor2-first=Hans |date=2010 |title=Corruption & Human Rights: Interdisciplinary Perspectives |chapter=Chapter III. Corruption and Human Rights: Making the Connection |publisher=Intersentia |isbn=9789400000858 |pages=25–50 }}</ref>

== Legal framework ==
In national and in international legislation, there are laws interpreted as directed against corruption. The laws can stem from resolutions of international organizations, which are implemented by the national governments, who are ratifying those resolutions or be directly issued by the respective national [[legislative]].

Laws against corruption are motivated by similar reasons that are generally motivating the existence of [[criminal law]], as those laws are thought to, on the one hand, bring justice by holding individuals accountable for their wrongdoing, justice can be achieved by sanctioning those corrupted individuals, and potential criminals are deterred by having the consequences of their potential actions demonstrated to them.<ref>{{cite book |last1=Miller |first1=Seumas |last2=Roberst |first2=Peter |last3=Spence |first3=Edward |title=Corruption and Anti-Corruption: An Applied Philosophical Approach |date=2005 |lccn=2004002505 |isbn=978-0-13-061795-8 |publisher=Pearson/Prentice Hall |page=128 }}</ref>

=== International law ===
Approaching the fight against corruption in an international setting is often seen as preferential over addressing it exclusively in the context of the [[nation state]]. The reasons for such preference are multidimensional, ranging from the necessary international cooperation for tracing international corruption scandals,<ref>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=208 et seq |language=en |url=https://www.osce.org/secretariat/232761 }}</ref> to the binding nature of international treaties, and the loss in relative competitiveness by outlawing an activity that remains legal in other countries.

==== OECD ====
{{Main|OECD Anti-Bribery Convention}}
The [[OECD Anti-Bribery Convention]] was the first large scale convention targeting an aspect of corruption, when it came in 1999 into force. Ratifying the convention obliges governments to implement it, which is monitored by the OECD Working Group on Bribery. The convention states that it shall be illegal bribing foreign public officials. The convention is currently signed by 43 countries. The scope of the convention is very limited, as it is only concerned with active bribing. It is hence more reduced than other treaties on restricting corruption, to increase – as the working group's chairman [[Mark Pieth]] explained – the influence on its specific target.<ref name=p59>International Anti-Corruption Norms, pp. 59 et seq.</ref> Empirical research by Nathan Jensen and [[Edmund Malesky]] suggests that companies based in countries that ratified the convention, are less likely to pay bribes abroad.<ref name=Jensen>{{cite journal |last1=Jensen |first1=Nathan M. |last2=Malesky |first2=Edmund J. |title=Nonstate Actors and Compliance with International Agreements: An Empirical Analysis of the OECD Anti-Bribery Convention |volume=72 |issue=1 |doi= 10.1017/S0020818317000443 |journal=[[International Organization]] |date=2017 |pages=33–69 |s2cid=158446483 }}</ref> The results are not exclusively explainable by the regulatory mechanisms and potential sanctions triggered through this process but are equally influenced by less formal mechanisms, e.g. the peer reviews by officials from other signatories and the potentially resulting influences on the respective country's image.<ref>International Anti-Corruption Norms, Chapter 2, pp. 59–95</ref> Groups like TI, however, also questioned whether the results of the process are sufficient, especially as a significant number of countries is not actively prosecuting cases of bribery.<ref>''Confronting Corruption'', pp. 94–95</ref>

==== United Nations ====
{{Main|United Nations Convention against Corruption}}
[[File:UNCACmap.svg|thumb|upright=1.25|alt=Color-coded world map of ratifiers signatories, and others in the United Nations Convention against Corruption|A world map depicting international participation in the UNCAC. {{unbulleted list|{{legend|#42ac89|Ratifiers}}|{{legend|#cdcd42|Signatories}}|{{legend|#ff0000|Not signed}}|{{legend|#e1e1e1|Others}}}}]]
20 years before the OECD convention was ratified, the [[United Nations]] discussed a draft for a convention on corruption. The draft on an international agreement on illicit payments proposed in 1979<ref>United Nations Conference on Trade and Development (2001): "Illicit Payments", UNCTAD Series on International investment agreements. p. 24</ref> by the [[United Nations Economic and Social Council]] did not gain traction in the [[United Nations General Assembly|General Assembly]], and was not pursued further.<ref>International Anti-Corruption Norms, p. 64</ref> When the [[UN Office on Drugs and Crime]] (UNODC) presented its draft of the [[United Nations Convention against Corruption]] (UNCAC) in 2003, it proved more successful. UNCAC was ratified in 2003 and became effective in 2005. It constitutes an international treaty, currently signed by 186 partners, including 182 member states of the United Nations and four non-state signatories. UNCAC has a broader scope than the OECD Anti-Bribery Convention, as it does not exclusively focus on public officials but includes inter alia corruption in the [[private sector]] and non-bribery corruption, like e.g. [[money laundering]] and [[abuse of power]]. UNCAC also specifies a variety of mechanisms to combat corruption, e.g. international cooperation in detecting and prosecuting corruption, the cancellation of permits, when connected to corrupt behavior, and the protection of [[whistleblower]]s. The implementation of UNCAC is monitored by the [[International Association of Anti-Corruption Authorities]] (IAACA)

==== International organizations ====
===== International Anti-Corruption Court =====
{{Main|International Anti-Corruption Court}}
[[Mark Lawrence Wolf]] floated in 2012 the idea to launch an [[International Anti-Corruption Court]], as either a part of the already existing [[International Criminal Court]], or as an equivalent to it. The suggestion was widely discussed and endorsed by a variety of NGOs including [[Global Organization of Parliamentarians Against Corruption]] (GOPAC), [[Global Witness]], [[Human Rights Watch]], the [[Integrity Initiatives International]] (III), and TI.<ref>{{cite web |last=Magistad |first=Mary Kay |title=Disrupting the Kleptocrat's Playbook, one investigative report at a time |date=April 21, 2017 |publisher=[[Public Radio International]] |access-date=September 12, 2018 |language=en |url=https://www.pri.org/stories/2017-04-21/disrupting-kleptocrats-playbook-one-investigative-report-time }}</ref> An implementation of the concept is currently not scheduled by any organizations with the authority of conducting such step.

===== Existing international organizations =====
In 2011, the [[International Anti-Corruption Academy]] was created as an [[intergovernmental organization]] by [[treaty]]<ref>{{cite book |last1=Schermers |first1=Henry G. |author-link1=Henry G. Schermers |last2=Blokker |first2=Niels M. |title=International institutional law : unity within diversity |year=2011 |publisher=Martinus Nijhoff Publishers |location=Boston |page=30 |language=en |isbn=9789004187962 |url=https://books.google.com/books?id=OMXToQLp21UC&q=%22International+anti-corruption+academy%22+%22Intergovernmental+organization%22+-iaca.int&pg=PA30 |access-date=September 17, 2018 |edition=5th }}</ref> to teach on anti-corruption topics.<ref>{{cite book|last1=Fletcher |first1=Clare |last2=Herrmann |first2=Daniela |title=The internationalisation of corruption : scale, impact and countermeasures |isbn=978-1-4094-1129-1 |publisher=Gower |date=2012 |language=en |page=2 }}</ref>

Many other intergovernmental organizations are working on the reduction of corruption without issuing conventions binding for its members after ratification. Organizations that are active in this field include, but are not limited to, the [[World Bank]] (such as through its [[Independent Evaluation Group]]), the [[International Monetary Fund]] (IMF),<ref>{{cite web |last=Thomson |first=Alistair |title=Beheading the Hydra: How the IMF Fights Corruption |url=https://blogs.imf.org/2017/05/18/beheading-the-hydra-how-the-imf-fights-corruption/ |date=May 18, 2017 |access-date=September 17, 2018 |language=en }}</ref> and regional organizations like the [[Andean Community]] (within the framework of the {{lang|es|Plan Andino de Lucha contra la Corrupción}}).<ref>{{cite news |title=Bolivia asume la presidencia del Parlamento Andino por un año |newspaper=[[Opinión]] |url=http://www.opinion.com.bo/opinion/articulos/2011/0809/noticias.php?id=20910 |access-date=September 17, 2018 |date=August 9, 2011 |language=es }}</ref>

==== Regulations by continental organizations ====
===== Americas =====
{{Main|Inter-American Convention Against Corruption}}
The first convention adopted against corruption by a regional organization was the [[Organization of American States]]' (OAS) [[Inter-American Convention Against Corruption]] (IACAC). The convention, which targeted both active and passive bribing, came into force in 1997. It is currently ratified by all 34 active OAS-Member States.<ref>{{cite web |url=http://www.oas.org/en/sla/dil/inter_american_treaties_B-58_against_Corruption_signatories.asp |title=List of signatories of IACAC |date=August 2009 |access-date=August 14, 2018}}</ref>{{efn|Cuba was suspended from the OAS from 1962 to 2009. After the ban on Cuba's participation was lifted in 2009, the country elected not to participate. See: [[Cuban relations with the Organization of American States]].}}

===== Europe =====
In 1997 the [[European Union]] (EU) adopted the EU Convention against corruption involving officials, which makes it illegal to engage in corrupt activities with officials from the European Union's administrative staff, or with officials from any member state of the EU. It forces the signatories to outlaw both active and passive bribing which involves any aforementioned official. Liability for unlawful actions is extend to the heads of those entities, whose agents were bribing officials.<ref>{{cite web |url=https://www.business-anti-corruption.com/anti-corruption-legislation/european-anti-corruption-conventions/ |title=European Anti-Corruption Conventions |access-date=August 10, 2018 |publisher=GAN Integrity |archive-date=September 21, 2018 |archive-url=https://web.archive.org/web/20180921230445/https://www.business-anti-corruption.com/anti-corruption-legislation/european-anti-corruption-conventions/ |url-status=dead }}</ref>

[[European states]] also ratified the [[Council of Europe]]'s [[Criminal Law Convention on Corruption|Criminal]] and [[Civil Law Convention on Corruption]], which were adopted in 1999. The former was an addition extended by passing the [[Additional Protocol to the Criminal Law Convention on Corruption]]. The two conventions on criminal law were signed by [[Belarus]] and all Council of Europe members, with the exception of [[Estonia]], which abstains from the Additional Protocol.{{efn|The [[Czech Republic]], [[Italy]] and the [[Russian Federation]] signed the Protocol but did so far not ratify it.<ref name=Criminal>{{cite web|url=https://www.coe.int/de/web/conventions/full-list/-/conventions/treaty/173/signatures?p_auth=GzSRsV7F |title=List of signatories of the Criminal Law Convention on Corruption |access-date=August 16, 2018 }}</ref><ref name=Protocol>{{cite web|url=https://www.coe.int/en/web/conventions/full-list/-/conventions/treaty/191/signatures?p_auth=GzSRsV7F |title=List of signatories of the Additional Protocol to the Criminal Law Convention on Corruption |access-date=August 16, 2018 }}</ref>}} The Criminal Law Convention is currently by 48 States, while the Additional Protocol is signed by 44 countries.<ref name=Criminal /><ref name=Protocol /> Both conventions are aiming at the protection of judicial authorities against the negative impact of corruption.<ref>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=16 |language=en |url=https://www.osce.org/secretariat/232761 }}</ref>

The convention on Civil Law is currently ratified by 35 countries, all of which are, with the exception of Belarus, members of the Council of Europe.<ref>{{cite web|url=https://www.coe.int/de/web/conventions/full-list/-/conventions/treaty/174/signatures?p_auth=GzSRsV7F |title=List of signatories of the Civil Law Convention on Corruption |access-date=August 16, 2018 }}</ref> As the name implies, it requires the States Parties to provide remedies for individuals materially harmed by corruption. The individual who was negatively impacted by an act of corruption is entitled to rely on laws to receive compensation from the culprit or the entity represented by the culprit, explicitly including the possibility of compensation from the state, if the corrupt deed was perpetrated by an official.<ref>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=11 et seq|language=en |url=https://www.osce.org/secretariat/232761 }}</ref> The anti-corruption efforts by the Council of Europe are supervised and supported by the [[Group of States Against Corruption]] (GRECO) as its main monitoring organization. Membership to GRECO is open to all countries worldwide and is not conditional on membership at CoE.

===== Africa =====
{{Main|African Union Convention on Preventing and Combating Corruption}}
Since its launch in 2003, the [[African Union]]'s [[African Union Convention on Preventing and Combating Corruption|Convention on Preventing and Combating Corruption]] was ratified by 38 States Parties.<ref>{{cite web |url=https://au.int/sites/default/files/treaties/7786-sl-african_union_convention_on_preventing_and_combating_corruption_5.pdf |title=List of signatories of the African Union Convention on Preventing and Combating Corruption |access-date=August 16, 2018 |archive-url=https://web.archive.org/web/20180628212120/https://au.int/sites/default/files/treaties/7786-sl-african_union_convention_on_preventing_and_combating_corruption_5.pdf |archive-date=June 28, 2018 |url-status=dead }}</ref> It represents the consensus of the signatories on minimal standards for combating corruption. The resolution was criticized in the [[Journal of African Law]] for disregarding other aspects of the rule of law, like e.g. [[data protection]] and the [[presumption of innocence]].<ref>{{cite journal |last=Schroth |first=Peter W.|date=2005 |title=The African Union Convention on Preventing and Combating Corruption |journal=[[Journal of African Law]] |volume=49 |issue=1 |pages=24–38 |jstor=27607931|doi=10.1017/S0021855305000033|s2cid=145296780}}</ref>

=== National law ===
While bribing domestic officials was criminalized in most countries even before the ratification of international conventions and treaties,<ref>{{cite book | title = OECD Bribery Awareness Handbook for Tax Examiners | publisher = OECD | date = 2009 | pages = 15 | language =en | url =https://www.oecd.org/tax/crime/37131825.pdf }}</ref> many national law systems did not recognize bribing foreign officials, or more sophisticated methods of corruption, as illegal. Only after ratifying and implementing above mentioned conventions the illegal character of those offenses was fully recognized.<ref>{{cite journal |last1=Pacini |first1=Carl |last2=Swingen |first2=Judyth A. |last3=Rogers|first3=Hudson |date=2002 |title=The Role of the OECD and EU Conventions in Combating Bribery of Foreign Public Officials |journal= [[Journal of Business Ethics]] |volume=37 |issue=4 |pages=385–405 |doi=10.1023/A:1015235806969 |s2cid=153579940 }}</ref> Where legislation existed prior to the ratification of the OECD convention, the implementation resulted in an increased compliance with the legal framework.<ref>{{cite journal |last1=Cuervo-Cazurra |first1=Alvaro |date=2008 |title=The effectiveness of laws against bribery abroad |journal=[[Journal of International Business Studies]] |volume=39 |issue=4 |pages=634–651 |doi=10.1057/palgrave.jibs.8400372 |s2cid=56422300 }}</ref>

Corruption is often addressed by specialized investigative or prosecution authorities, often labelled as [[List of anti-corruption agencies|anti-corruption agencies]] (ACA), that are tasked with varying duties and subject to varying degrees of independence from the respective government, regulations, and powers, depending on their role in the architecture of the respective national law enforcement system. One of the earliest precursors of such agencies is the anti-corruption commission of [[New York City]], which was established in 1873.<ref name=Graycar4>{{cite book |last1=Graycar |first1=Adam |last2=Prenzler |first2=Tim |year=2013 |chapter=Chapter 4: The Architecture of Corruption Control |title=Understanding and Preventing Corruption |series=Crime Prevention and Security Management |language=en |publisher=Palgrave Macmillan UK |pages=50–69 |doi=10.1057/9781137335098 |isbn=978-1-137-33508-1 }}</ref> A surge in the numbers of national ACAs can be noted in the last decade of the 20th and the first decade of the 21st century.<ref>{{cite web |last=Heilbrunn |first=John R. |title=Anti-Corruption Commissions Panacea or Real Medicine to Fight Corruption? |url=http://siteresources.worldbank.org/WBI/Resources/wbi37234Heilbrunn.pdf |access-date=August 30, 2018 |agency=[[World Bank Institute]] |language=en |date=2004 }}</ref>

==== Armenia ====
In 2019 Armenian Government approved Anti-Corruption Strategy and its implementation plan between 2019 and 2022.<ref>{{cite web |title=On approving the Republic of Armenia Anti-Corruption Strategy and its implementation action plan for 2019-2022 |url=https://www.moj.am/storage/files/pages/pg_7105326429691_Anti-Corruption_Strategy_03.10.2019_ENG.pdf |publisher=Government of the Republic of Armenia |archive-url=https://web.archive.org/web/20210512150231/https://www.moj.am/storage/files/pages/pg_7105326429691_Anti-Corruption_Strategy_03.10.2019_ENG.pdf |archive-date=May 12, 2021 |date=2019 |url-status=dead}}</ref>
Under this strategy the three main directions will be the prevention of corruption, the corruption crimes investigation, anticorruption education and awareness of the corruption and anticorruption strategy. Even before adoption of Anti-Corruption Strategy and implementation plan, after 2018 Velvet Revolution, number of criminal investigation cases of corruption almost doubled in Armenia. As Prosecutor General's Office issued report says, the number of corruption investigations started by law enforcement agencies in the country during the first half of 2018 is more than double compared with the number of the criminal cases against corruption cases started during the first half of 2017. Out of the 786 cases initiated in the beginning of 2018 - 579 resulted in criminal cases. Starting from the first months of the anticorruption plan implementation, Armenia carried out actions in the fight against corruption - which was mainly directed to improve the investment environment of Armenia, and as a result economic indexes were improved.<ref>{{Cite web|url=https://www.coe.int/en/web/corruption/anti-corruption-digest/armenia|title = Anti-corruption digest Armenia}}</ref>

==== Brazil ====
{{Main|Brazilian Anti-Corruption Act}}
{{Expand section |date=January 2020}}

Brazil's [[Brazilian Anti-Corruption Act|Anti-Corruption Act]] (officially "Law No. 12,846" and commonly known as the Clean Company Act") was enacted in 2014 to target corrupt practices among business entities doing business in Brazil. It defines civil and administrative penalties, and provides the possibility of reductions in penalties for cooperation with law enforcement under a written leniency agreement signed and agreed to between the business and the government. This had major implications in [[Operation Car Wash]], and resulted in major agreements such as the [[Odebrecht–Car Wash plea bargain agreements]] and the recovery of billions of dollars in fines.<ref>{{cite web |language=pt |last1=Bedinelli |first1=Talita |url=http://brasil.elpais.com/brasil/2016/12/21/politica/1482347716_003844.html |website=El País |trans-title=Odebrecht and Braskem to pay the highest fine for corruption in history |title=Odebrecht e Braskem pagarão a maior multa por corrupção da história |date=21 December 2016 |access-date=23 January 2020}}</ref>

==== Canada ====
[[Canada]] remained one of the last signatories of the OECD-convention on bribery that did not implement its national laws against bribes for foreign officials.<ref>''Confronting Corruption'', p. 98</ref> While the [[Corruption of Foreign Public Officials Act]] (CFPOA) was passed in 1999, it was often not used to prosecute foreign bribery by Canadian companies, as the bill had a provision that the act of bribery had to have a "real and substantial link" with Canada. Such provision was canceled in 2013 by the Bill S-14 (also called Fighting Foreign Corruption Act). Additionally, Bill S-14 banned facilitation payments and increased the possible punishment for violating the CFPOA.<ref>{{cite news |last1=Ramsay |first1=Christopher J |last2=Wilson |first2=Clark |title=The Anti-Bribery and Anti-Corruption Review – Edition 6: CANADA |date=January 2018 |publisher=The Law Reviews |url=https://thelawreviews.co.uk/edition/the-anti-bribery-and-anti-corruption-review-edition-6/1151845/canada |access-date=August 20, 2018 |language=en |archive-date=September 21, 2018 |archive-url=https://web.archive.org/web/20180921225932/https://thelawreviews.co.uk/edition/the-anti-bribery-and-anti-corruption-review-edition-6/1151845/canada |url-status=dead }}</ref> An increase in the maximum prison sentence for bribery to 14 years was one of the increases in sanctioning.<ref name=Aiolfi>{{cite book |last1=Aiolfi |first1=Gemma |editor1-last=Brodowski |editor1-first=Dominik |editor2-last=Espinoza de los Monteros de la Parra |editor2-first=Manuel |editor3-last=Tiedemann |editor3-first=Karl |editor4-last=Vogl |editor4-first=Joachim |title=Regulating Corporate Criminal Liability |publisher=Springer |date=2014 |pages=125–134 |chapter=Mitigating the Risks of Corruption Through Collective Action |isbn=978-3-319-05992-1 |doi=10.1007/978-3-319-05993-8_11}}</ref> According to TI's report from 2014, Canada is moderately enforcing the OECD Convention against bribery.<ref name=Vogl />

==== China ====
In the wake of [[economic liberalization]], corruption increased in [[China]] because anti-corruption laws were insufficiently applied.<ref>{{cite journal |last1=Gong |first1=Ting |last2=Zhou |first2=Na |date=2015 |title=Corruption and marketization |journal=[[Regulation & Governance]] |volume=9 |pages=63–76 |doi=10.1111/rego.12054 }}</ref> The [[Anti-corruption campaign under Xi Jinping|anti-corruption campaign that started in 2012]], however, changed the relation towards corruption. This campaign led to increased press coverage of the topic and a sharp increase in court cases dedicated to the offense. The campaign was primarily led by the [[Central Commission for Discipline Inspection]] (CCDI), an internal body of the [[Communist Party of China|Communist Party]] and secondarily by the [[People's Procuratorate]].<ref>{{cite journal |last=Chen |first=Lyric |title=Who Enforces China's Anti-corruption Laws? Recent Reforms of China's Criminal Prosecution Agencies and the Chinese Communist Party's Quest for Control |journal=Loyola of Los Angeles International & Comparative Law Review |year=2017 |volume=40 |issue=2 |issn=1533-5860 |pages=139–166 |language=en }}</ref> CCDI cooperated with investigative authorities in several ways, such as passing incriminating material detected by its internal investigation, to prosecutors.

The underlying legal regulations for the campaign is rooted in provisions of the Anti-Unfair Competition Law and the [[Law of the People's Republic of China#Criminal Law|criminal law]].

==== Georgia ====
From 2003 to 2012, [[Georgia (country)|Georgia]] moved from one of the ten most-corrupt countries based on [[Corruption Perceptions Index]] rankings to among the top third for clean government. Anti-corruption reforms implemented by president [[Mikheil Saakashvili]] resulted in the firing of all 16,000 traffic police officers in a single day, simplification of government bureaucracy, and university entrance based on standardized exams rather than interviews.<ref>{{cite journal|doi=10.1080/09668136.2016.1192107|title=Administrative Cohesion and Anti-Corruption Reforms in Georgia and Ukraine|year=2016|last1=Nasuti|first1=Peter|journal=Europe-Asia Studies|volume=68|issue=5|pages=847–867|s2cid=156813675}}</ref> Laws in Georgia that deal with corruption include Articles 332&ndash;342 of its Criminal Code, the Law of Georgia on the Conflict of Interests and Corruption in Public Service, Money Laundering Law, and Law of Georgia on the Conflict of Interests and Corruption in Public Service (Art. 20).<ref>{{cite web|url=https://www.ganintegrity.com/portal/country-profiles/georgia/| title=Georgia Corruption Report| date=August 2020| access-date=6 April 2021| website=Risk & Compliance Portal|publisher=GAN Integrity}}</ref> The trajectory of Georgia from highly corrupt to much cleaner governance supports the notion that piecemeal anti-corruption reforms are less effective than anti-corruption initiatives with broad scope.<ref>{{cite journal|doi=10.1146/annurev-environ-012320-083949|doi-access=free|title=Corruption and Anti-Corruption in Environmental and Resource Management|year=2020|last1=Tacconi|first1=Luca|last2=Williams|first2=David Aled|journal=Annual Review of Environment and Resources|volume=45|pages=305–329|hdl=1885/264140|hdl-access=free}}</ref>

==== Japan ====
After signing the OECD-Convention on Combating Bribery of Foreign Public Officials,<ref>{{Cite web|url=https://www.oecd.org/daf/anti-bribery/ConvCombatBribery_ENG.pdf|title=Convention on Combating Bribery of Foreign Public Officials in International Business Transactions|date=2011|website=OECD}}</ref> [[Japan]] implemented the Unfair Competition Prevention Act (UCPA) to comply with the convention. The law states that it is illegal to bribe foreign public officials. The individual who was offering the bribes and the company on whose behalf the bribes were offered may face negative consequences. The Company Act also enables the punishment of senior management if the payment was made possible by their [[negligence]]. Transparency International criticized Japan in 2014 for not enforcing the law, hence only complying to the convention on paper and providing no consequences to offenders.<ref name=Vogl /> Nevertheless, a study conducted by Jensen and Malesky in 2017 provides empirical evidence that Japanese companies are less involved in bribery than companies based in other Asian countries that did not sign the convention.<ref name=Jensen />

==== United Kingdom ====
The [[United Kingdom]] was a founding member of the OECD working group on bribery and ratified the Anti-Bribery Convention, but faced significant problems in complying to its findings and the convention.<ref>International Anti-Corruption Norms, p. 61</ref> It was severely affected by the [[Al-Yamamah arms deal]], in which the British company [[BAE Systems]] faced allegations of having bribed members of the [[Saudi Arabia|Saudi]] [[House of Saud|royal family]] to facilitate an arms deal. British prosecution of BAE Systems was stopped after an intervention by then Prime Minister [[Tony Blair]], which caused the OECD working group to criticize the British anti-corruption laws and investigations.{{citation needed|date=April 2019}}

The [[UK Bribery Act of 2010]] came into force on July 1, 2011, and replaced all former bribery-related laws in the United Kingdom. It is targeting bribery and receiving bribes, both towards national and foreign public officials. Furthermore, it is assigning responsibility to organizations whose employees are engaging in bribing and hence obliges companies to enforce [[Regulatory compliance|compliance]]-mechanisms to avoid bribing on their behalf. The Bribery Act goes in many points beyond the US-American FCPA, as it also criminalizes [[facilitation payment]]s and private sector corruption inter alia.<ref name=Compliance17>{{cite book |last=Bleker-van Eyk |first=Sylvie C. |editor1-last=Bleker-van Eyk |editor1-first=Sylvie C. |editor2-last=Houben |editor2-first=Raf A. M. |title=Handbook of Compliance & Integrity Management |publisher=Kluwer Law International |date=2017 |pages=311–324 |chapter=Chapter 17: Anti-Bribery & Corruption |isbn=9789041188199}}</ref> Heimann and Pieth are arguing that British policy makers supported the Bribery Act to overcome the damage in reputation caused by the Al-Yamamah deal.<ref>''Confronting Corruption'', p. 93</ref> Sappho Xenakis and Kalin Ivanov on the other hand claim that the negative impact on the UK's reputation was very limited.<ref>{{cite journal |last1=Xenakis |first1=Sappho |last2=Ivanov |first2=Kalin |title=Does Hypocrisy Matter? National Reputational Damage and British Anti-Corruption Mentoring in the Balkans |journal=[[Critical Criminology (journal)|Critical Criminology]] |volume=25 |issue=3 |pages=433–452 |doi=10.1007/s10612-016-9345-4 |issn=1205-8629 |language=en |year=2016 |s2cid=151952105 |url=http://eprints.bbk.ac.uk/15796/3/15796.pdf }}</ref>

Transparency International stated in 2014 that the United Kingdom fully complied to the OECD Convention against Bribery.<ref name=Vogl />

==== United States ====
Already at the foundation of the [[United States]] discussions on the possibility of preventing corruption were held, leading to increased awareness for corruption's threads. [[Title of Nobility Clause|Article 1, Section 9]] of the [[United States Constitution|Constitution]] can be seen as an early anti-corruption law, as it outlawed the acceptance of gifts and other favors from foreign governments and their representatives. [[Zephyr Teachout]] argued that giving and receiving presents held an important role in [[diplomacy]] but were often seen as potentially dangerous to a politician's integrity.<ref>{{cite book |last=Teachout |first=Zephyr |author-link=Zephyr Teachout |date=2014 |title=Corruption in America|publisher=Harvard University Press|isbn=978-0-674-05040-2|pages=17 et seq}}</ref> Other early attempts to oppose corruption by law were enacted after the end of [[World War II]]. The [[Bribery and Conflict of Interest Act]] of 1962 for example regulates the sanctions for bribing national officials, respectively the acceptance of bribes by national officials, and the abuse of power for their personal interest. The [[Hobbs Act]] of 1946 is another law frequently applied by US-American prosecutors in anti-corruption cases. Prosecutors are using the act by arguing that the acceptance of benefits for official acts qualifies as an offence against the act. Less frequently laws to prosecute corruption through auxiliary criminal activities include the [[Mail Fraud Statute]] and the [[False Statements Accountability Act]].<ref>{{cite book |last1=Miller |first1=Seumas |last2=Roberst |first2=Peter |last3=Spence |first3=Edward |title=Corruption and Anti-Corruption: An Applied Philosophical Approach |date=2005 |lccn=2004002505 |isbn=978-0-13-061795-8 |publisher=Pearson/Prentice Hall |page=130 }}</ref>

In 1977, the [[United States of America]] adopted the [[Foreign Corrupt Practices Act]] (FCPA), which criminalized corrupt interactions with foreign officials. Since its implementation, the law served to prosecute domestic and foreign companies, who bribed officials outside of the United States. As no other country implemented a similar law up to the 1990s, US-American companies faced disadvantages for their global operations. In addition to the legal status of corruption abroad, many countries also treated bribes as [[tax-deductible]]. Through applying the law to companies with ties to the United States and by working on global conventions against foreign bribery, the government of the US tried to reduce the negative impact of FCPA on US-American companies.<ref>''Confronting Corruption'', pp. 72 et seq.</ref>

Alongside the FCPA, additional laws were implement that are directly influencing anti-corruption activities. Section 922 of the [[Dodd–Frank Wall Street Reform and Consumer Protection Act]] for instance extents the [[Securities Exchange Act of 1934]] by a new Section 21F that protects whistleblowers from retaliation and grants them financial awards them when collaborating with the [[Securities and Exchange Commission]] (SEC). Conway-Hatcher et al. (2013) attributed an increase the number of whistleblowers, who are reporting to SEC, inter alia on corruption incidents to the provision.<ref>{{cite book |last1=Conway-Hatcher |first1=Amy| last2=Griggs |first2=Linda |last3=Klein |first3=Benjamin |editor1-last=Del Debbio |editor1-first=Alessandra |editor2-last=Carneiro Maeda |editor2-first=Bruno |editor3-last=da Silva Ayres |editor3-first=Carlos Henrique |title=Temas De Anticorrupção e Compliance |publisher=Elsevier |date=2013 |pages=251–267 |chapter=Chapter 12: How whistleblowing may pay under the U.S. Dodd-Frank Act: implications and best practices for multinational companies |isbn=9788535269284}}</ref>

The TI's last report on enforcement of the OECD Convention against bribery published in 2014 concluded that the United States are complying with the convention.<ref name=Vogl>{{cite news |last=Vogl |first=Frank |title=Trade Trumps Anti-Corruption |date=2014 |publisher=[[Huffington Post]] |url=https://www.huffingtonpost.com/frank-vogl/trade-trumps-anticorrupti_b_6075936.html?guccounter=1 |access-date=August 24, 2018 }}</ref>

In 2011 the [[American Anti-Corruption Act]] was drafted, written in part by former [[Federal Election Commission]] chairman [[Trevor Potter]], with input from dozens of strategists, reformers and constitutional attorneys from across the ideological divide, as a type of [[model legislation]] to limit or outlaw practices which contribute to political corruption.<ref name="twsWaPo14569">{{cite news | author= Helena Andrews-Dyer| date= February 27, 2019| newspaper= The Washington Post| url= https://www.washingtonpost.com/arts-entertainment/2019/02/27/actress-jennifer-lawrence-lays-out-plan-save-america/| title= Actress Jennifer Lawrence lays out a plan to save America| accessdate= January 21, 2022| quote= ...Settle down, class: Professor Lawrence will school you now....}}</ref> The idea was to craft a blueprint law that could be adapted by numerous jurisdictions at the state and local levels that was consistent with the current constitutional structure and that would make it easier to identify and limit political corruption. It is supported by nonprofit nonpartisan reform organizations such as [[RepresentUs]].<ref name="twsMJ2143">{{cite web| author= GAVIN ARONSEN| date= November 13, 2012| publisher= Mother Jones| url= https://www.motherjones.com/politics/2012/11/represent-us-campaign-finance-reform/| title= New Group Unveils Its Plan to Get Money Out of Politics| accessdate= January 21, 2022| quote= ... Represent.Us says its goal is to pass the American Anti-Corruption Act...}}</ref>

== Governmental anti-corruption beyond the law ==
=== Prevention of corruption/anti-corruption ===
[[Values education]] is believed to be a possible tool to teach about the negative effects of corruption and to create resilience against acting in a corrupt manner, when the possibility of doing so arises.<ref>''Confronting Corruption'', p. 217</ref> Another stream of thought on corruption prevention is connected to the economist [[Robert Klitgaard]], who developed an economic theory of corruption that explains the occurrence of corrupt behavior by producing higher gains than the assumed punishment it might provoke. Klitgaard accordingly argues for approaching this rational by increasing the costs of corruption for those involved by making fines more likely and more severe.

=== Good governance ===
As corruption incidences often happen in the interaction between representatives of private sector companies and public officials, a meaningful step against corruption can be taken inside of public administrations.<ref name=":0" /> The concept of [[good governance]] can accordingly be applied to increase the [[integrity]] of administrations, decreasing hence the likelihood that officials will agree on engaging in corrupt behavior.<ref name=GG>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=55 et seq |language=en |url=https://www.osce.org/secretariat/232761 }}</ref> Transparency is one aspect of good governance.<ref>{{cite web |last=Rubbra |first=Alice |title=What makes good governance? #2 in series: Why transparency in governance is so important |url=http://www.rightforeducation.org/all-topics/law-governance/good-governance-transparency/ |access-date=September 4, 2018 |language=en |publisher=R:Ed |date=19 April 2017}}</ref> Transparency initiatives can help to detect corruption and hold corrupt officials and politicians accountable.<ref>{{cite journal |last=Schnell |first=Sabina |title=Cheap talk or incredible commitment? (Mis)calculating transparency and anti‐corruption |journal=[[Governance (journal)|Governance]] |year=2018 |volume=31 |issue=3 |language=en |doi=10.1111/gove.12298 |issn=0952-1895 |pages=415–430 }}</ref>

Another aspect of good governance as a tool to combat corruption lies in the creation of trust toward state institutions. Gong Ting and Xiao Hanyu for instance argue that citizens, who have a positive perception of state institutions are more likely to report corruption-related incidents than those, who express lower levels of trust.<ref>{{cite journal |last1=Gong |first1=Ting |last2=Xiao |first2=Hanyu |title=Socially Embedded Anti-Corruption Governance: Evidence from Hong Kong |journal=Public Administration & Development |year=2017 |volume=37 |issue=3 |doi=10.1002/pad.1798 |issn=0271-2075 |pages=176–190 |language=en |doi-access=free }}</ref>

=== Sanctions ===
Even though [[Sanctions (law)|sanction]]s seem to be underwritten by a legal framework, their application often lies outside of a state-sponsored legal system since they are frequently applied by [[International financial institutions#Multilateral Development Banks|multilateral development banks]] (MDBs), state agencies, and other organizations, which implement those sanctions not through applying laws, but by relying on their internal bylaws. [[World Bank]], even though reluctant in the 20th century to use sanctions,<ref>''Confronting Corruption'' pp.49 et seq.</ref> turned into a major source of this specific kind of applying anti-corruption measures.<ref>''Confronting Corruption'', p. 214</ref> the involved MDBs are typically applying an administrative process that includes judicial elements, when a suspicion about corruption in regard to the granted projects surfaces. In case of identifying a sanctionable behavior, the respective authority can issue a [[debarment]] or milder forms, e.g. mandatory monitoring of the business conduct or the payment of fines.<ref>''Confronting Corruption'' pp. 213 et seq.</ref>

=== Public sector procurement ===
Excluding companies with a track record of corruption from [[bidding]] for contracts, is another form of sanctioning that can be applied by procurement agencies to ensure compliance to external and internal anti-corruption rules.<ref>''Confronting Corruption'', p. 223</ref> This aspect is of specific importance, as public procurement is both in volume and frequency especially vulnerable for corruption. In addition to setting incentives for companies to comply with anti-corruption standards by threatening their exclusion from future contracts, the internal compliance to anti-corruption rules by the procurement agency has central importance. Such step should according to anti-corruption scholars Adam Graycar and Tim Prenzler include precisely and unambiguously worded rules, a functional protection and support of whistleblowers, and a system that notifies supervisors early about the potential dangers of conflicts of interest or corruption-related incidents.<ref>{{cite book |last1=Graycar |first1=Adam |last2=Prenzler |first2=Tim |year=2013 |chapter=Chapter 7: Preventing Corruption in Public Sector Procurement |title=Understanding and Preventing Corruption |series=Crime Prevention and Security Management |language=en |publisher=Palgrave Macmillan UK |pages=100–113 |doi=10.1057/9781137335098 |isbn=978-1-137-33508-1 }}</ref>

== Civil society ==
Michael Johnston, among others, argued that [[non-governmental organization]]s (NGOs), [[Civil Society Organization]]s (CSOs), and the [[Mass media|media]] can have an efficient influence on the level of corruption.<ref>{{cite book |editor-last=Johnston |editor-first=Michael |title=Civil Society and Corruption: Mobilizing for Reform |date=2005 |publisher=University Press of America |isbn=978-0-7618-3125-9 }}</ref> More over, Bertot et al. (2010) extended the list of potentially involved agents of civil society by introducing the notion of decentralized, non-formally organized anti-corruption activism through [[social media]] channels.<ref>{{cite journal |last1=Bertot |first1=John C. |last2=Jaeger |first2=Paul T. |last3=Gimes |first3=Justin M. |title=Using ICTs to create a culture of transparency: E-government and social media as openness and anti-corruption tools for societies |journal=Government Information Quarterly |volume=27 |issue=3 |doi=10.1016/j.giq.2010.03.001 |year=2010 |pages=264–271 |language=en |doi-access=free }}</ref>

Taking into consideration that precise and comprehensive definitions of corrupt actions are lacking, the legal perspective is structurally incapable of efficiently ruling out corruption. Combined with a significant variety in national laws, frequently changing regulations, and ambiguously worded laws, it is argued that non-state actors are needed to complement the fight against corruption and structure it in a more holistic way.<ref name=Graycar4 />

=== Ensuring transparency ===
An example for a more inclusive approach to combating corruption that goes beyond the framework set by lawmakers and the foremost role taken by representatives of the civil society is the monitoring of governments, politicians, public officials, and others to increase [[Transparency (behavior)|transparency]]. Other means to this end might include pressure campaigns against certain organizations, institutions, or companies.<ref>{{cite journal |last=Büthe |first=Tim |date=2004 |title=Governance through private authority? Non-state actors in world politics |journal=[[Journal of International Affairs]] |volume=58 |issue=1 |pages=281–290 |url=https://people.duke.edu/~buthe/downloads/Buthe_JIA_corrected.pdf |access-date=August 28, 2018 |archive-date=July 26, 2020 |archive-url=https://web.archive.org/web/20200726070728/https://people.duke.edu/~buthe/downloads/Buthe_JIA_corrected.pdf |url-status=dead }}</ref> [[Investigative journalism]] is another way of identifying potentially corrupt dealings by officials. Such monitoring is often combined with reporting about it, in order to create [[publicity]] for the observed misbehavior. Those mechanisms are hence increasing the price of corrupt acts, by making them public and negatively impacting the image of the involved official. One example for such strategy of combating corruption by exposing corrupt individuals is the [[Albania]]n television show ''[[Fiks Fare]]'' that repeatedly reported on corruption by airing segments filmed with hidden cameras, in which officials are accepting bribes.<ref>{{cite journal |last=Musaraj |first=Smoki |title=Corruption, Right On! Hidden Cameras, Cynical Satire, and Banal Intimacies of Anti-corruption |journal=[[Current Anthropology]] |year=2018 |volume=59 |pages=105–116 |doi=10.1086/696162 |s2cid=148598894 |issn=0011-3204 |language=en }}</ref>

=== Education on corruption ===
Another sphere for engagement of civil society is the prevention by educating about the negative consequences of corruption and a strengthening of ethical values opposing corruption. Framing corruption as a moral issue used to be the predominant way of fighting it but lost importance in the 20th century as other approaches became more influential.<ref>{{cite journal |last=Bardhan |first=Pranab |author-link=Pranab Bardhan |title=Corruption and Development: A Review of Issues |year=1997 |journal=Journal of Economic Literature |volume=35 |issue=3 |pages=1320–1346 |jstor=2729979 |language=en }}</ref><ref>Bacio Terracino (2012), pp. 29-31</ref> The biggest organization in the field of civil societal opposition towards corruption is the globally active NGO [[Transparency International]] (TI).<ref>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=142 et seq |language=en |url=https://www.osce.org/secretariat/232761 }}</ref> NGOs are also providing material to educate practitioners on anti-corruption. Examples for such publications are the rules and suggestions provided by the [[International Chamber of Commerce]] (ICC), the [[World Economic Forum]] (WEF), and TI.<ref>''Confronting Corruption'', p. 224</ref> Persistent work by civil societal organizations can also go beyond establishing a knowledge about the negative impact of corruption and serve as way to build up political will to prosecute corruption and engage in counter-corruption measures.<ref>{{cite book |last1=Ayogu |first1=Melvin |chapter=Non-state actors and value recovery: Ganging up political will |editor1-last=Thelesklaf |editor1-first=Daniel |editor2-last=Gomes Pereira |editor2-first=Pedro |year=2011 |title=Non-State Actors in Asset Recovery |language=en |pages=93–108 |publisher=Peter Lang |isbn=978-3-0343-1073-4 }}</ref>

=== Non-state actors in the field of asset recovery ===
{{Main|International asset recovery}}
One prominent field of activism for non-state actors (NSAs) is the area of [[international asset recovery]], which describes the activity of returning property to its legitimate owners after it was illegally acquired through corrupt actions. The process describes the whole procedure from gathering information on the criminal offence that initiated the transfer of assets, over their confiscation to their return. While recovery is mandated by UNCAC, it is not an activity singularity conducted by governments but attracts actors with different backgrounds, including [[academia]], the media, CSOs, and other non state actors. In this field of anti-corruption activism, representatives of the civil society are often taking a different stance than in other areas, as they are regularly consulted for assisting administrations with their respective expertise and are hence enabling state actions. Such strong role of NSAs was also recognized by UNCAC's States Parties.<ref>{{cite book |last1=Gomes Pereira |first1=Pedro |last2=Roth |first2=Anja |last3=Attisso |first3=Kodjo |chapter=A stronger role for non-state actors in the asset recovery process |editor1-last=Thelesklaf |editor1-first=Daniel |editor2-last=Gomes Pereira |editor2-first=Pedro |year=2011 |title=Non-State Actors in Asset Recovery |language=en |pages=1–15 |publisher=Peter Lang |isbn=978-3-0343-1073-4 }}</ref>

== Corporate anti-corruption approaches ==
=== Compliance ===
{{Main|Regulatory compliance}}
Instead of relying purely on deterrence, as suggested by Robert Klitgaard (see [[#Prevention of corruption/anti-corruption|section on prevention]]), [[economist]]s are pursuing the implementation of [[incentive]] structures that reward [[Regulatory compliance|compliance]] and punish the non-fulfillment of compliance rules. By aligning the self-interest of the agent with the societal interest of avoiding corruption, a reduction in corruption can thus be achieved.<ref>{{cite book |last=Teichmann |first=Fabian Maximilian Johannes |date=2017 |title=Anti-Bribery Compliance Incentives |publisher=Kassel University Press |isbn=978-3-7376-5034-2 |pages=102 et seq |language=en }}</ref>

The field of compliance can generally be perceived as an internalization of external laws in order to avoid their fines. The adoption of laws like the FCPA and the UK Bribery Act of 2010<ref>{{Cite web|url=https://www.legislation.gov.uk/ukpga/2010/23/contents|title=Bribery Act 2010|website=www.legislation.gov.uk|language=en|others=Expert Participation|access-date=2018-10-07}}</ref> strengthened the importance of concepts like compliance, as fines for corrupt behavior became more likely and there was a financial increase on these fines. When a company is sued because its employers engaged in corruption, a well-established compliance system can serve as proof that the organization attempted to avoid those acts of corruption. Accordingly, fines can be reduced, which incentivizes the implementation of an efficient compliance system.<ref name=Compliance17 /> In 2012, the US-authorities decided not to prosecute [[Morgan Stanley]] in a case of bribery in China under FCPA-provisions due to its compliance program.<ref name=Aiolfi /> This case demonstrates the relevance of the compliance approach.

=== Collective action ===
Anti-corruption collective action is a form of [[collective action]] with the aim of combatting corruption and bribery risks in [[Government procurement|public procurement]]. It is a collaborative anti-corruption activity that brings together representatives of the private sector, public sector and civil society. The idea stems from the academic analysis of the [[prisoner's dilemma]] in [[game theory]] and focuses on establishing rule-abiding practices that benefit every stakeholder, even if unilaterally each stakeholder might have an incentive to circumvent the specific anti-corruption rules. Transparency International first floated a predecessor to modern collective action initiatives in the 1990s with its concept of the ''Island of Integrity'', now known as an [[integrity pact]].<ref>{{cite book |title=The Integrity Pact |publisher=Transparency International |date=2016 |language=en |url=https://transparency.hu/wp-content/uploads/2016/04/The-Integrity-Pact-ENG.pdf }}</ref> According to Transparency International, "collective action is necessary where a problem cannot be solved by individual actors" and therefore requires stakeholders to build trust and share information and resources.<ref>{{cite book |title=Collective Action on Business Integrity |publisher=Transparency International |date=2018 |language=en |url=https://www.transparency.org/whatwedo/publication/collective_action_on_business_integrity }}</ref>

The World Bank Institute states that collective action "increases the impact and credibility of individual action, brings vulnerable individual players into an alliance of like-minded organizations and levels the playing field between competitors.<ref>[https://www.globalcompact.de/wAssets/docs/Korruptionspraevention/Publikationen/fighting_corruption_through_collective_action.pdf ''World Bank Institute: Fighting Corruption Through Collective Action'']</ref>

Anti-corruption collective action initiatives are varied in type, purpose and stakeholders but are usually targeted at the supply side of bribery.<ref>{{Cite web|url=https://www.collective-action.com/resources/collective_action|title=B20 Collective Action Hub|accessdate=June 19, 2023|archive-date=December 29, 2019|archive-url=https://web.archive.org/web/20191229090341/https://www.collective-action.com/resources/collective_action|url-status=dead}}</ref> They often take the form of collectively agreed anti-corruption declarations or standard-setting initiatives such as an industry [[code of conduct]]. A prominent example is the [[Wolfsberg Group]] and in particular its ''Anti-Money Laundering Principles for Private Banking and Anti-Corruption Guidance'', requiring the member banks to adhere to several principles directed against money laundering and corruption. The mechanism is designed to protect individual banks from any negative consequences of complying with the strict rules by collectively enforcing those regulations. The Wolfsberg Group in addition serves as a back-channel for communication between the compliance officers of the participating banks.<ref>''Confronting Corruption'', pp. 225 et seq.</ref> The World Economic Forum's initiatives against corruption can also be seen in this framework.<ref>{{cite book |title=OSCE Handbook on Combating Corruption |publisher=OSCE |date=2016 |pages=155 |language=en |url=https://www.osce.org/secretariat/232761 }}</ref> Other initiatives in the field of collective action include the [[Extractive Industries Transparency Initiative]] (EITI), [[Construction Sector Transparency Initiative]]/[[Infrastructure Transparency Initiative]] (CoST) and [[International Forum on Business Ethical Conduct]] (IFBEC).<ref>''Confronting Corruption'' pp.226-227</ref> Collective action is included in the national anti-corruption statements of the UK,<ref>{{cite web |title=United Kingdom National Statement, International Anti-Corruption Conference |url=https://iaccseries.org/wp-content/uploads/2018/10/United_Kingdom_National_Statement_2018.pdf |archive-url=https://web.archive.org/web/20221006034257/https://iaccseries.org/wp-content/uploads/2018/10/United_Kingdom_National_Statement_2018.pdf |archive-date=October 6, 2022 |date=October 22, 2018 |url-status=live}}</ref> France,<ref>{{cite web |title=National Anti-Corruption Statement: France |url=https://iaccseries.org/wp-content/uploads/2018/10/France_National_Statement_2018-2.pdf |archive-url=https://web.archive.org/web/20221002161007/https://iaccseries.org/wp-content/uploads/2018/10/France_National_Statement_2018-2.pdf |archive-date=October 2, 2022 |url-status=live}}</ref> and Ghana,<ref>{{cite web |title=Statement from the Delegation from Ghana at the high level Anti-Corruption Conference in Copenhagan |url=https://iaccseries.org/wp-content/uploads/2018/10/Ghana_National_Statement_2018.pdf |archive-url=https://web.archive.org/web/20221006034257/https://iaccseries.org/wp-content/uploads/2018/10/Ghana_National_Statement_2018.pdf |archive-date=October 6, 2022 |url-status=live}}</ref> delivered at the [[International Anti-Corruption Conference]] 2018.

The [[List of G20 summits#B20 summits|B20]] policy interventions are another form of engaging in the anti-corruption discourse, as B20 members are attempting to support the [[G20]] by offering their insights as business leaders, including in regard to strengthening anti-corruption policies, e.g. transparency in government [[procurement]] or more comprehensive anti-corruption laws.<ref>{{cite book |title=OSCE Handbook on Combating Corruption |last=Stukalo |first=Alexey |publisher=OSCE |date=2016 |pages=155 et seq |language=en |url=https://www.osce.org/secretariat/232761 }}</ref> In 2013, the B20 mandated the [[Basel Institute on Governance]] to develop and maintain the B20 Collective Action Hub, an online platform for anti-corruption collective action tools and resources including a database of collective action initiatives around the world. The B20 Collective Action Hub is managed by the Basel Institute's International Centre for Collective Action (ICCA) in partnership with the [[UN Global Compact]].

Another tangible outcome of the B20 meetings was the discussion (and implementation as a test case in [[Colombia]]) of the [[High Level Reporting Mechanism]] (HLRM), which aims to implement a form of [[ombudsman]] office in a high-level government position for companies to report possible bribery or corruption issues in public procurement tenders.<ref>''Confronting Corruption'', pp. 238-239</ref> As well as Colombia, the HLRM concept has been implemented in different ways in Argentina, Ukraine and Panama.<ref>{{Cite web|url=https://b20-dev.baselgovernance.org/explore/hlrm|title=Collective Action - B20 hub|website=b20-dev.baselgovernance.org|accessdate=June 19, 2023}}</ref>

=== Implementation ===
Sylvie Bleker-van Eyk from [[VU University Amsterdam]] sees value in the implementation of strong compliance departments in the respective company.<ref name=Compliance17 /> Fritz Heimann and Mark Pieth are described the environment where those departments are working, as being in a best cased monitored from outside experts.<ref>''Confronting Corruption'' p. 233</ref> Another measure that – according to Heimann and Pieth – supports the work of compliance officers is when the company is joining collective action initiatives.<ref name="CC Collective Action">''Confronting Corruption'', pp. 235 et seq.</ref> Instruments like [[ethical code]]s can serve as underlying documents to promote support for anti-corrupt corporate policies. Seumas Miller et al. (2005) also stress the process of reaching the aspired result, which should include an open discussion among the employees of a company, in order to implement steps that are approved by consent inside of the company.<ref>{{cite book |last1=Miller |first1=Seumas |last2=Roberst |first2=Peter |last3=Spence |first3=Edward |title=Corruption and Anti-Corruption: An Applied Philosophical Approach |date=2005 |lccn=2004002505 |isbn=978-0-13-061795-8 |publisher=Pearson/Prentice Hall |page=139 }}</ref> Such shift in culture can be implemented through and accompanied by exemplary behavior by top management, regularly conducted training programs on anti-corruption and a constant monitoring of the development in those sections.<ref>''Confronting Corruption'' p. 232</ref>

== In culture ==
{{Main|International Anti-Corruption Day}}
[[International Anti-Corruption Day]] has been annually observed on [[December 9]] since the United Nations established it in 2003 to underline the importance of anti-corruption and provide visible sign for anti-corruption campaigns.<ref>{{cite web |url=http://www.anticorruptionday.org/actagainstcorruption/index.html |access-date=August 14, 2018 |publisher=UNODC |title=Main page of the campaign for an International Anti-Corruption Academy }}</ref>

== See also ==
* [[ISO 37001|ISO 37001 Anti-bribery management systems]]
* [[Group of States Against Corruption]]
* [[International Anti-Corruption Academy]]
* [[International Anti-Corruption Day]]
* [[United Nations Convention against Corruption]]
* [[OECD Anti-Bribery Convention]]
* [[Subsidy#Preventing fraud|Preventing fraud in subsidies]]
* [[RepresentUs]]

== Notes ==
{{Notelist}}

== References ==
{{Reflist}}

== Sources ==
* {{cite book |last=Bacio Terracino |first= Julio |title=The international legal framework against corruption : states' obligations to prevent and repress corruption |year=2012 |publisher=Intersentia |isbn=978-1-78068-092-7 |oclc=810879652 |language=en }}
* {{cite book |last=Rose |first=Cecily |year=2015 |title=International Anti-Corruption Norms |publisher=Oxford University Press |isbn=978-0-19-873721-6 |oclc=908334497}}
* {{cite book |year=2016 |editor-first=Alexey |editor-last=Stukalo |title=OSCE Handbook on Combating Corruption |location=Vienna |publisher=[[Organization for Security and Co-operation in Europe]] |url=https://www.osce.org/secretariat/232761 |isbn=978-92-9234-192-3 |oclc=964654700}}
* {{cite book |last1=Heimann |first1=Fritz |last2=Pieth |first2=Mark |year=2018 |orig-year=2017 |title=Confronting Corruption |publisher=Oxford University Press |isbn=978-0-19-045833-1 |oclc=965154105}}
* {{Cite journal | doi=10.1080/00220388.2020.1849622 | journal=Journal of Development Studies| volume=57| pages=1373–1396| year=2021| last1=Diwan| first1=Ishac| last2=Haidar| first2=Jamal Ibrahim|url=https://www.tandfonline.com/doi/full/10.1080/00220388.2020.1849622|title=Political Connections Reduce Job Creation: Firm-level Evidence from Lebanon| issue=8| s2cid=229717871}}

[[Category:Anti-corruption measures| ]]

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