The OECD recently released its 2011 Data on Enforcement of the Anti-Bribery Convention, available here. It contains a number of fascinating, and surprising, results. To show you what I mean, see how many of the following answers you get right. (Note: the questions adopt the report’s use of the word “sanctions” to describe enforcement actions resolved against the defendant).
1. True or false: Germany sanctioned more natural persons than the U.S.
2. After the U.S. and Germany, which country had the highest number of total sanctions?
3. True or false: Korea sanctioned four times as many persons (natural and legal) as the U.K.
4. Of Australia and Italy, one sanctioned 13 persons in 2011, while the other sanctioned zero. Which is which?
5. True or false: Bulgaria sanctioned more natural persons than the following countries COMBINED: Argentina, Australia, Austria, Brazil, Canada, Chile, Czech Republic, Denmark, Estonia, Finland, Greece, Iceland, Ireland, Israel, Luxembourg, Mexico, Netherlands, New Zealand, Poland, Slovak Republic, Slovenia, South Africa, Spain, and Turkey.
* * *
1. True: 73 versus 58.
3. True: 20 versus 5.
4. Italy 13, Australia 0.
5. True: 1 versus 0.
Andy Spalding is the senior editor of the FCPA Blog. A former Fulbright Senior Research Scholar in Asia, he’s Assistant Professor at the University of Richmond School of Law.