The Sleeping Dog Stirs: New Signs of Life in Efforts to End Corruption in International Business

Abstract

For many years, international firms and executives treated the Foreign Corrupt Practices Act (FCPA) as the proverbial sleeping dog, best left alone. The FCPA was perceived as an overreaching and naïve attempt by the U.S. government to impose unrealistic moral standards on global business conduct. The statute was regarded as unenforced and unenforceable. Recently, however, the U.S. government has stepped up FCPA prosecutions. International organizations, such as the International Monetary Fund, the Organization of Economic Cooperation and Development (OECD), and Transparency International also have increased global interest in and efforts to combat corrupt business practices. In November 1997, OECD member nations and others signed an agreement that committed them to changing their national laws to fight bribery. This increased activity should be an early warning signal to executives that demonstrates the higher risk of exposure of and the higher level of legal and business consequences for corrupt practices.