The international effort to combat bribery – particularly of foreign government officials by corporate entities – began in earnest in 1997 with the United Nation's adoption of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the Anti-bribery Convention).
However, the last decade has seen highly resourced and some would say an aggressive focus on prosecution of companies and individuals in relation to corrupt conduct, particularly by the US Department of Justice pursuant to the US Foreign Corrupt Practices Act which has resulted in many multi-million dollar settlements.
Most recently, we have seen the UK government's renewed vigor to target this conduct with its introduction of the UK Bribery Act (which came into force in July 2011).
Even Australia, which has been notably inactive in prosecuting its equivalent laws that have been in place for at least two decades, has finally in late 2011 brought its first...