Global efforts to stop fraud and bribery in international business transactions have currently accelerated. The Organization for Economic Co-operation and Development (OECD) has been leading the fight on corruption in international businesses. From as early as 1989, the OECD began its anti-bribery agenda. This was due to its conviction that bribery in international trade and investment was common and had harmful consequences. On 17 December 1997, OECD signed the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention or Anti-Bribery Convention).The convention is the only and the first anti-corruption instrument internationally. The Convention’s legal characteristics are first indicated in its focus on active bribes rather than passive brides.
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This implies that the convention combats bribery offences of the parties who offer or promise to give brides. It has no interest in the parties that accept bribes. In essence, the convention calls for all nations involved to criminalize bribery actions of all foreign officials, come up with suitable sanctions for violations and concur on enforcement and extradition of those charged with the bribery offence. The convention assists in assuring that there is a certain level of similarity in the parties’ initiatives to fight against the bribery of foreign public officials. It implies that parties do not have to possess similar basic principles in their legal systems or implement uniform changes. On November 2009, the Council adopted the Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions. The recommendations apply to member countries as well as other nations that are party to the Convention. The recommendation provides both general and specific recommendations that further assist parties in fighting bribery offences as outlined in the Anti- Bribery Convention.
Fraud and Bribery
Fraud involves any activity undertaken by a person illegally or in a dishonest way to provide an advantage to the person. Similarly, from its definition, bribery involves the wrongful actions taken towards influencing an official or any person in charge of legal or public duty. It is characterized by giving, offering, soliciting or receiving something that is worth a given value. The public official does not have to accomplish the act of receiving the item for the offence of bribery to be complete (Nadipuram 5).
Fraud and bribery hamper economic growth and hinders advancements in business. The World Bank highlights that each year more than $1 trillion brides in total are paid globally, representing about 3% of the world economy. In reality, bribery is so widespread that bribes result to about a 20 percent tax on foreign investments (D’Souza 76). The problem forces firms and other types of businesses to spend higher costs while transacting with foreign countries. Certainly, fraud and bribery is a multinational concern that has seen various international and intergovernmental organizations create treaties or conventions whose objective is to criminalize and prevent bribery. Establishment of an efficient multilateral policy is appropriate in complementing efforts by various countries to combat corruption (Nadipuram 8).
The OECD efforts in fighting fraud and bribery
The OECD is the leader in the fight against international fraud and bribery. It has taken the initiative to provide a unified and comprehensive front against corruption through its various instruments. It functions as an international organization that guides member its Nations and non-member nations in combating corruption in international business transactions. The OECD tackles the issue of corruption from the position of those receiving wrongful payments through the public service work and those providing these payments and takes action against the bribe givers (D’Souza 75).
This report examines the legal aspects of two of the OECD instruments that help in fighting corruption internationally. One of them is the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Anti-Bribery Convention). The Convention that was signed in 1997 and adopted in 1999 by both member and non-member countries helps in detecting and preventing acts of bribery (Leipziger 337). By 2013, thirty-nine nations were party to the convention, they comprised of thirty-four member countries of OECD and five non-member countries. The member countries consist of some of the largest economies in the world such as United States, Germany, Japan and the United Kingdom. Another instrument is the OECD Recommendations for Further Combating Bribery of Foreign Public Officials in International Business Transactions. The instrument was adopted in 2009 by parties of the Anti-Bribery Convection to enhance their ability in preventing, detecting and investigating of any alleged foreign bribery. The recommendations provide additional measures that reinforce the parties’ efforts at combating bribery offences. The main objective of these two documents is to ensure that firms doing international business have a fair business environment (Nadipuram 9)
The Anti-Bribery Convention and Recommendations of Further Combating Bribery of Foreign Pubic Officials have certain legal aspects. One of its significant legal aspects is the convention’s requirement that all parties signatory to it should identify and define the acts of a criminal offence in bribery and ascertain the liability of a legal person for the offence. Other additional provisions mainly reinforce this obligation by facilitating its successful application and enforcement. The recommendations provide some general and specific requirements that a Party can use to enhance the provisions of the Convention (D’Souza 78). Therefore, the various legal characteristics are derived from the Convention and its Recommendation, while in the application of the fight against bribery offences.
The Anti-Bribery Convention legal aspects involve; identifying and defining what constitutes an act of bribery among the foreign public officials; describing the responsibility of the legal parties; sanctions for the bribery of foreign public officials; parties’ determination of their jurisdiction; available enforcements against the offenses; and finally co-operation between parties and extradition. Legal aspects of 2009 adopted recommendations are contained in the general recommendations and specific recommendations including; criminalizing bribery offences, issues of tax deductibility, reporting of bribery offences, Companies Accounting and Auditing Requirements, Internal Controls, Ethics and Compliance, the public advantage in public functions and international co-operation (D’Souza 81).
Legal aspects of OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions
Definition of the offence of Bribery of Foreign public officials
In defining acts of bribery, the Convention applies the law broadly and touches on any entity conducting business globally. It has established certain standards that the parties have to abide by when defining a bribery offence. However, they can use other terms under their laws to define the offence provided it meets the elements of the convention (Nadipuram 12). According to article 1, any act by an entity or individual to promise or offer a bribe to a public official in a foreign nation with the intention of keeping or getting business should be criminalized. Such an act will result in an offence whether committed directly or with the assistance of an intermediary.
Individuals or entities found to have participated in one way or another to the act of bribery shall be found guilty of a criminal offence. It implies that third party who did not necessarily take part in offering or promising the bribe shall also be found guilty. For instance, they may have facilitated the bribe to take place by introducing the offender to the foreign public official. The acts should be committed in the course of carrying out official duties (Nadipuram 13). It will also involve the use of an official public position within or outside the confinements of that office. However, if there is any written law, case law or regulation of the foreign public official that permits such an advantage, the act will not be considered an offense. Here, the convention displays its limitation in scope since parties cannot prosecute offenders as long as they do not have a law within its legal system that prohibits bribery. The OECD encourages such parties to establish laws that will not limit the convention in serving its purpose (Nadipuram 14).
The convention provides for exoneration from criminal liability persons who voluntarily report bribery acts and those who assist in investigating bribery of public officials. For this reason, the Convention effectiveness is enhanced because it provides reprieve to offenders willing to co-operate. It provides the characteristics of a foreign public official as any person who holds elective positions in a foreign nation’s legislature, executive, administrative of a judicial body or any other person serving in the public functions. Public functions are the activities that a legal person is delegated to perform by a foreign country to fulfill its public interest, like the public procurement function. A foreign country is referred to as any subdivision within a country’s government from national to local (Spahn 36).
Therefore, to the signatories, the Convention must apply to all persons and must involve an entity giving a gift or payment in a corrupt manner with the intention of wrongfully influencing the recipient. Thus, it focuses on the intent of the actor and it does not matter whether the actual bribe took place. In reality, the one paying the bribe will be liable even when the foreign official has not solicited, accepted or received the corrupt payment. The influence, in this case, could be to get something that was not rightly deserved such as obtaining a license. It could also be for enabling a company to carry out a business that it has not met the statutory requirements. In fulfilling their obligation in prosecuting legal persons who have committed the offence of bribery, member countries are allowed to use various ways based on the legal principles applicable to their country. However, they have to convict an individual based on elements that prove the offence as it is described in the convention. For instance, in case a party has a statute that prohibits acts of bribery by their agents, such a statute is considered to comply with the elements of the convention.
Determining the responsibility of Legal Persons
Article 2 of the Convention obliges member countries to determine the liability of a legal person who participates in the bribing of public officials. The Convention does not define the term legal person; instead, it directs that state parties should refer to their national law to understand the term (Nadipuram 18). They have the liberty to use their legal principles in describing a legal person. For instance, a legal person mainly refers to a fictitious person such as a body corporate or natural person, as a human being. There are also certain characteristics that can be used in determining whether an entity or individual is a legal person and subject to prosecution. For example, a natural person, in this case, should have attained a certain number of years preferably 18 years of age. Additionally, to be a body corporate, the formation and registration of a business enterprise should be as per a country’s legal system.
The convention is not very precise in articulating the minimum standards that apply while establishing the liability of legal persons. A party is required to apply those standards that abide by its fundamental legal principles and legal systems. Parties are not obliged to establish any criminal responsibility in cases where their legal systems do not account for finding a legal person with criminal responsibility. Although the Convention does not provide a clear definition of the term legal person, it provides guidelines to parties that will assist in defining this term. The parties will then be able to apply their laws and the elements of the convention to prosecute legal persons who commit an offence of bribery of public officials (Spahn 41).
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The convention outlines the requirements for coming up with the necessary punishment for the bribery offence. Article 3 highlights that penalties for these punishments should be effectively determined to match the offence of bribing a foreign public official. These penalties shall also be in agreement with the laws of bribing public officials in each of the nations (Nadipuram 22). The convention provides a provision for countries whose legal systems that do not apply criminal responsibility to prosecute legal persons. In this case, non-criminal sanctions can apply and includes imposing financial sanctions. Besides, a party is obliged to ensure that the proceeds obtained through bribery are confiscated. Other assets of a similar value with these proceeds may also be confiscated, or sanctions of a similar monetary effect are applied.
Member parties are also required to impose any other type of sanction to prosecute bribery offenders including civil and administrative penalties within their legal systems. These sanctions may involve disqualifying them from participating in public procurement or engaging in any commercial activities, either permanently or temporally. Parties are required to allow offenders to have legal representation during their prosecution. It is considered as an entitlement for any legal entity undergoing such a legal process. It will ensure that all parties are fair and objective while issuing the sanctions. The Convention provision to explain the sanctions applicable in prosecuting offenders are to the Parties is very essential. It will assist parties in determining the magnitude of the offences committed and provide penalties that are comparable to the offence. The sanctions will also assist in trying to restore the parties to their original state before the offence was committed.
Article 4 explains the measures used to establish the jurisdiction of each nation to enable it prosecute acts of bribing foreign public officials. The offense may have been committed either in part or entirely within the Party’s territory. Additionally, the article requires countries to include within their legal system new changes that will enable it exercise its jurisdiction properly. Member and non-member signatories apply certain measures to establish the appropriate jurisdiction for prosecuting offences committed abroad. Laws of one Party may be used in prosecuting offences of bribery of foreign officials’ from other countries. This allows parties to put on trial nationals who commit crimes abroad (Nadipuram 23).
Under this article, parties are obliged to conduct evaluations on the present status of its jurisdiction to find out whether it is effective in fighting against bribery offences. The necessary rectifications are done to make sure a party has enough jurisdictions to combat bribery. This calls for amendment of anti-bribery laws by member and non-member countries to include the prohibition of bribery of foreign officials. In the event that more than one country has jurisdiction over the crime, the article requires member countries to co-operate by consulting one another to establish the most suitable jurisdiction for the prosecution. Constant reviews by the parties are significant for the convention to become applicable. Various provisions of the convention can only be effectively applied after parties review, evaluate and determine their jurisdiction properly (Pacini and Judyth 134)
Article 5 deals with enforcement by describing how the process of investigating and prosecuting bribery acts should comply with the suitable rules and principles of each country. This process should be free from interferences like economic interests of the nation, relations or identity of that legal person involved in the investigations and legal proceedings. According to Article 6, in the event that a deadline for filing a lawsuit exists, such a deadline shall provide that adequate time is allowed for investigations and subsequent prosecutions take place. Article 7 explains that a state can use money-laundering legislation to prosecute acts of bribery. The legislation shall be deemed to be broadly applied meaning that it prosecutes its public officials in bribery offences. In this case, the same shall be used in prosecuting other acts of bribery of foreign public officials in total disregard of where the bribery has taken place (Pacini and Judyth 139).
Article 8 is related to Section V of the 1997 OECD recommendations. It discusses how parties should enforce laws and regulations in their local companies accounting and auditing functions. Firstly, member countries should ensure that they have established the right steps that all companies follow in forming and establishing their businesses. The steps should also define the manner in which companies will conduct both local and foreign business transactions. This includes ensuring companies have the right legal structures that are used in preventing and detecting any acts of bribery of foreign public officials. The legal structures should follow the basic legal principles of the country and be within its jurisdiction
In accounting, OECD convention cannot impose and reinforce certain measures and practices of accounting since parties have different accounting and auditing practices. Instead, it proposes a set of accounting and auditing standards that parties should follow to prevent bribery. These acts of bribery are likely to be committed through companies’ accounting documents (Spahn 39).
Parties are required to come up with laws and regulations that limit companies from committing acts of bribing foreign public officials. The laws should also enhance revelation of acts of bribery. They should ensure companies maintain proper books and records, discloses everything in their financial reporting and follow the accounting and auditing standards. In case companies are found to do contrary to the laws and regulations, member nations are obliged to apply their civil, administrative and criminal penalties to punish them accordingly. The introduction of various laws helps in stopping misrepresentations or omissions in accounting books. Finally, they allow financial statements of companies to be subjected to investigations and scrutiny increasing the chances of detecting any acts of fraud or bribery. Enforcement in the convention takes care of all conflicts that are likely to arise in the implementation of the parties laws. The convention provides provisions that are supposed to ensure that there is smooth enforcement of the parties’ laws. It plays a critical role in law since the Convention would not be successful without proper enforcement of the provisions (Pacini and Judyth 146).
International Co-operation and Extradition
Article 9 to 11 discusses the legal co-operation that is needed between countries as well as extradition. Article 9 discusses the Mutual Legal Assistance that obligates parties to provide each other any necessary legal assistance. The assistance will be useful in investigating and bringing legal proceedings for criminal and non-criminal offences that are within the scope of the convention. Parties should provide each other any valuable legal assistance like giving additional information and documents as requested. In some instances, a signatory to the Convention can make a condition dictating that the Party only offers Mutual Legal Assistance to another Signatory only if there is Dual criminality. Thus, to satisfy this condition, Dual criminality will then be deemed to exist. Signatories should also not use the condition to maintain bank secrecy as a reason for not providing Mutual Legal Assistance to other signatories for criminal issues within the scope of the Convention (Spahn 45).
Article 10 requires parties to take the offence of bribing a foreign public official as an offence that requires extradition under the laws in which such an offence occurs and those of the treaties between parties. Some member and non-member nations have a condition that they can only carry out extradition if they have an extradition treaty. Other parties can make a request to such parties to assist in the extradition of its offenders. In this case, this request can be honored using the Convention as the legal base of extradition. If a party does not extradite an offender because the person is a national, then such an offender shall be prosecuted according to the laws applied by national authorities of that Party. In case there is the condition of dual criminality before a party makes extradition, the condition will be considered as fulfilled as long as the acts of the offender can be defined as bribery of foreign official under the Convention (Spahn 46).
Article 11 explains the instances when parties should notify and seek the assistance of the Secretary-General of OECD while requiring the co-operation of another party. In this case, the secretary general assists parties by establishing the right channels of communication when parties need to consult to determine the jurisdiction that is most suitable in prosecuting an alleged offence in which more than one party has jurisdiction. Secondly when needing mutual legal assistance or in the case of extradition. The convention cannot be successful without the co-operation of all parties. A combined effort by all parties will be more effective in combating bribery offences. The co-operation will also raise more awareness in the fight against bribery since all offences of one party can be prosecuted in a different country (Spahn 46).
Legal aspects of OECD Recommendations for Further Combating of Foreign Public Officials in International Business Transactions
A party to the convention is advised to continue doing what is necessary for preventing and detecting acts of bribery. According to the first article in the convention, this entails criminalizing the acts of bribery. Next, a party is directed to take useful measures according to its jurisdiction and other fundamental legal principles while keenly reviewing certain areas for successful implementation of the convention. These areas include raising awareness in both the private and public sector to prevent and detect foreign bribery, constantly review their criminal laws and their application in prosecuting offenders to match the Convention requirements. They should also evaluate their tax legislation, regulations, and practices to eliminate any possible acts of foreign bribery. This is supported by recommendation VIII and the council’s recommendations on tax measures for further combating bribery of foreign public officials.
They should put in place measures that see to it that acts of foreign bribery are reported to competent legal authorities. Parties are advised to ensure companies have compliance requirements that are set during its formation. The requirements provide guidance in the areas of accounting, external audit, ethics and internal controls. The council advises parties to create laws that can regulate banks and other financial institutions. These laws ensure that the institutions main proper books of accounts that can be availed anytime for auditing purposes. Parties are directed to ensure there are no acts of bribery related to any public functions such as public procurement. It is appropriate for parties to have civil, commercial and administrative laws and regulations established to fight foreign bribery will be appropriate for parties. Finally, parties are advised to have international co-operation in investigating and bringing legal proceedings in foreign bribery offences. These recommendations are meant to continue to enhance the provisions of the Anti-Bribery Convention in the fight against bribery.
To criminalize the offence of bribery of foreign officials
A party is advised to evaluate their laws occasionally and their approach to enforcing them while implementing the OECD Anti-Bribery Convention. This boosts their effectiveness in combating the offence of bribery. Parties are advised to act as soon as possible on facilitation payments that may have little effects in the present but have a huge impact in the future. Thus, to make sure the rule of law is upheld in this area, member countries and non-member countries should oblige their companies to review their policies constantly.
This will be aimed at helping companies to stop making small facilitation payments. A proper policy would ensure that such payments are made illegal. Then they are accurately reflected in the books of accounts and financial records of the companies. Finally, all parties are urged to raise enough awareness that stops public officials from engaging in domestic bribery through small facilitation payments. In achieving this, the Council recommends that a party should establish solicitation laws that assist in stopping the solicitation and acceptance of small facilitation payments. This recommendation describes further, what a bribery offence involves. Thus, this recommendation particularly discourages the use of small facilitation fees since they result in wrongful acts in gaining an advantage.
Members are urged to adopt some measures on the issue of tax deductibility. They are advised to establish an effective legal and administrative framework that helps in enforcing the provisions of the Convention. This provision specifically helps in disallowing tax deductibility of bribes offences. These should also allow reporting of suspicious acts of bribery to the domestic law enforcement authorities.
Reporting offence of foreign bribery
The Council recommends that a party should make sure persons are provided with an easily accessible channel that enables them to reach the law enforcement authorities without problems. They should put in place suitable measures that enable public officials especially those working in foreign countries to manage giving reports to the law enforcement authorities either directly or indirectly. Additionally, it recommends that persons from the public and private sector willing to report acts of bribery be also assured of their right to protection against discrimination and disciplinary actions (Leipziger 338).
Companies Accounting and Auditing Requirements, Internal Controls, Ethics and Compliance
The Council recommends that a party should ensure there are suitable laws and regulations used for regulating companies accounting practices. This assists further in prevention and detection of bribery acts of foreign public officials by the companies. Further, the recommendation states the accounting requirements that companies need for compliance purposes. As explained in article 8 of the Anti-Bribery Convention, parties should ensure there is regulation of companies accounting practices within its legal framework. These laws should adequately support the efforts of detecting and preventing bribery of foreign officials. Hence, they should prohibit falsification of accounts, wrong identification of objects in records of liabilities among others. Moreover, parties need to come up with laws that support full disclosure of all company’s contingent liabilities in their financial statements. Parties should establish civil and administrative or criminal laws to penalize any acts of falsification of accounting books records or financial statement of such companies (Leipziger 332).
All companies are required to have an independent external audit. An external audit has certain requirements that should be adequately met by the companies as per the existing laws. Parties and their professionals associations are required to guarantee the independence of their external auditors by adhering to certain standards. This will contribute to objective examination and assessment of companies’ compliance with the necessary accounting standards. Parties should obligate the external auditors to report to management and appropriate authorities any discovered suspicion of acts of bribery of foreign public officials. The Council recommends that nations should encourage good response by companies’ management after receiving their reports from external auditors. They should ensure that auditors who have reported suspected acts of bribery of foreign public officials are protected from legal action when they report to law enforcement or regulatory authorities (Leipziger 334).
The recommendations on companies’ internal controls, ethics and compliance, advise parties to establish compliance programs, internal controls and ethics. These items will see to it that acts of bribery will be detected and prevented in time. Additionally, parties are encouraged to obligate their companies to make statements in their annual reports or openly disclose to the public about these programs. The program will highlight their measures of internal controls, compliance programs and ethics that assist in preventing and detecting bribery. Parties should have monitoring bodies like the board of directors and audit committees that cannot be influenced by management. Appropriate communication channels need to be available for individuals who for various reasons are not able to report acts of bribery. The reasons could be the presence of hierarchical pressure from superiors and the unwillingness to violate one’s professional standards. They will help their legal systems in identifying and evaluating the activities of companies (Pacini and Judyth 149).
Public advantage, including public procurement
This recommendation entails measures that a Party should follow to make sure there are no bribery offences in the process of securing public contracts. This is especially in the public procurement function where persons are likely to look for advantages. In this case, a party is advised to employ the same laws and regulations that prohibit the public officials to commit acts of bribery. Companies that are identified to have used a bribe in securing these contracts should be suspended and the right sanctions employed on them. It will ensure there is fair and transparent competition for public contracts and other public advantages like the public procurement contracts. Thus, the national laws are used in prosecuting entities that have bribed foreign public officials A party should ensure there are anti-corruption provisions in bilateral aid-funded procurement. They should also support the efforts of OECD in the enhancement of integrity and transparency in Public Procurement. This includes adhering to the other relevant international standards such as the European Union and World Trade Organization (WTO) (Brewster 84).
The council provides additional measures that assist parties in working together to fight effectively against acts of bribery of foreign. The co-operation should be in agreement with their jurisdictional and basic legal principles. These measures include consulting and co-operating with law enforcers in other countries to investigate and prosecute offenders. This may involve international and regional law enforcement networks of both member and non-member countries. They should co-operate in investigations and other legal proceedings in cases of bribery and make sure that their national laws support the possibility of co-operation as per Article 9 and 10 of the Convention. It recommends that they come up with ways of facilitating mutual legal assistance between member nations and with non-member nations in the event of bribery cases. This may entail regarding evidentiary thresholds for some member countries (Spahn 18)
The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the Recommendations of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions are essential tools in curbing bribery of foreign public officials. The Convention has assisted in providing a framework through which bribery is criminalized. It also helps to treatise commitment of the member countries to enhance a positive impact on international businesses. Member countries and non-member countries party to the Convention have to apply the legal characteristics in the Convention and Recommendations to establish the offence of bribing a foreign public official.
First, the Anti-Bribery Convention focuses on defining what involves anti-bribery. It does this in the framework of international business transactions that involve foreign public officials. Therefore, the Convention is applicable in preventing such acts and behaviors that are within the elements the convention of defining bribery acts. Secondly, the convention assists to establish that bribery is a criminal offence. Thirdly, it covers the sanctions that are applied towards a legal person involved in the act. Besides, it examines the jurisdiction covered by the parties. Fifth, the convention supports legal assistance between parties as well as extradition due to the bribery offence (Pacini and Judyth 133). The Council enhances the provisions provided under the Convention using its recommendations. First, they recommend a set of reviews and evaluations such as the Party’s jurisdiction and laws. Secondly, it provides specific recommendations that enhance the detection and prevention of bribery of foreign public officials.
The major concerns of the Convention are that it does not deal with the criminalization of the act of accepting bribes. This limits its scope in prosecuting all acts of bribery. The Convention provides that if a local law permits a bribe, then such a bribe should no longer considered an offence. Moreover, it does not deal with individuals who are about to occupy the public office or the subsidiaries of OECD countries operation outside their jurisdiction. Nevertheless, the Convention and the subsequent recommendations of the Council play a great role in fighting acts of bribery of foreign public officials. This assists in ensuring a better and safer business environment for international businesses.
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