Enforcers’ Ongoing Efforts to Combat Convergent Competition and Corruption Risks

As globalization washed through emerging markets in the early twenty-first century, antitrust and anticorruption were among the chief compliance risks daunting many multinational companies. Jurisdictions worldwide adopted or reinvigorated comprehensive competition statutes, often with peer support through the International Competition Network (“ICN”) and multilateral bodies such as the OECD. Enforcement actions under the U.S. Foreign Corrupt Practices Act (“FCPA”) intensified, fueling en