Abstract
The USA vigorously enforces its Foreign Corrupt Practices Act (FCPA), increasingly on an extraterritorial basis. The application of the FCPA to persons and circumstances outside the territory of the US shapes international anti-corruption efforts in ways that may run counter to effective governance practices and meaningful anti-corruption reform in the global economy. This short essay explores three aspects of FCPA enforcement which detract from the broader goals of global anti-corruption governance: the narrow conception of corruption upon which the FCPA is based, the strategic trade frame which underlies the FCPA’s internationalization, and the legitimacy problems these raise.
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